so we were actually besties in high school and started dating senior year! i always say he's my best friend but i start to feel bad when his parents treat me more like his little friend and mine treat him as such. it might be because of appearances? he is a trans man whos only been hormonally transitioning for two years and i dont consider myself a cis woman but thats what everyone automatically assumes. i hate when i'm out with my other guy friends and randos will assume we're dating but it never happens with my actual bf. it feels demeaning, and i guess it doesn't matter what other people think but as i'm getting older, it starts to feel more upsetting.

I’m 20F, and technically the only child of my parents(61F and 67M). I have a half sister(38F) that I share my mom with, however she has cut me off ever since she started her transitioning journey-she used to be a male- plus she lives in the UK. I have been always supportive of her, but obviously I cannot force her to keep in touch with me.
My parents and I moved to the US when I was 14 from Turkey. They do not know how to speak English nor do we have a house or anything here. They’ve been trying to make some money with the minimum wage jobs my uncle gives them, but obviously that is not enough. I worked hard enough to put myself through high school and college, and now I have landed a job at the Fed that guarantees me some stability. However, government jobs, especially when entry level, do not pay enough.
I do not know how I’ll be able to afford an apartment that will fit us all that is considerably close to the city. I do not want to send them back to Turkey, because I freak out at the thought of something happening to one of them and me not being there. I rarely get to enjoy myself when I go out due to the same lurking thought. I cannot travel abroad, because I feel horrible that I’m leaving them behind all while my peers are taking world tours.
All of this is so debilitating, and driving me to depression. The fact that I have to worry about my parents, money, being alone while everybody gets to enjoy themselves kills me. I cannot even get to pursue a PhD, which is something I have always wanted to do, because I need to be able to make money to take care of my parents. I feel so alone, and I do not know how to cope
I apologize that my thoughts are all over the place; I have way too many grievances that stem from being an only child that probably will not fit into a single Reddit post

EVSOL the new crypto utility token with real asset value to support electric vehicle infrastructure worldwide. A logical perception to improve on the reduction of carbon emission to zero and our dependence of fossil fuel for a clean environment will be overshadowed by the excessive price of electricity.
When the human population slowly transit to electric vehicles and billions of cars are charging, imagine the price of electricity will be. It doesn't matter when it will happen, it will occur and whoever position themselves early benefits from this innovation.
The human population must pay a tax for a cleaner environment for future generations there is no denying that. The tax is high electricity prices in future. Every household and every person around the world will plugin and charge everything chargeable causing a strain on global electricity grids.
Sola panels wind turbines is not enough even tidal generators would not keep up with demand the alternative is nuclear. This is the direction the human population would need to progress toward our dependency on electricity.
Anyone with a reasonable understanding will conclude the future is based on electricity. A century from Nikola Tesla Thomas Edison and JP Morgan Banking empire comes down to this, Nikola Tesla wanted electricity to be free. Thomas Edison discredited Nikola for fame and JP Morgan wanted to sell electricity, today we discover our future and environment is constrained from carbon emission with incapable electricity grid(s) to support a global population growth and advancement towards human standards of living.
There is no doubt over populated countries with constrained power grid(s) and nuclear bans will concede to build nuclear power plants. This view is inevitable, like I said above, to improve our environment and a higher standard of living to switch from a carbon base society to a electrical society demands a tax, therefore, whoever adopts this token will indeed be position in the market with this token will be a strong currency in the future.

🍁🏡 Ready Roofing: Ottawa's Roofing Solution 🏡🍁
Hey Ottawa, is your roof ready for our notorious weather? Get Ready Roofing on the job!
✅ Local, insured, and experienced roofing professionals. ✅ No-strings-attached FREE estimates. Transparency is our policy. ✅ High-quality materials to withstand Ottawa's diverse climate. ✅ 24/7 customer service. We're your neighbors here to help.
🚀 Reddit Special: Mention this post for a special discount on your first service! 🚀
Contact me personally at 613-203-4150 or [email protected] to get started today!

Thinking about moving to Georgia? You’re in good company – this southern state has been named one of the best places to live in the United States for several years running. In this guide, we’ll take a closer look at what makes Georgia so special, from its diverse cultural attractions to its affordable cost of living. We’ll also share practical tips and advice for making your move as stress-free as possible.

Reasons to Move

Georgia is a great place to call home for many reasons. The state boasts a warm climate, low cost of living, and a thriving job market. Plus, with top-ranked universities, a rich history, and a diverse arts and culture scene, there’s always something to see and do in Georgia. Whether you’re looking for a bustling city or a quiet suburb, Georgia has a place for you.

1. Affordable Cost of Living: Georgia is one of the most affordable states to live in the United States. With a low cost of living and a variety of housing options, you can stretch your budget further in Georgia than in many other states.
2. Thriving Job Market: Georgia has a diverse economy, with opportunities in industries such as healthcare, technology, and logistics. The state is home to several Fortune 500 companies, including Coca-Cola, Delta Air Lines, and Home Depot.
3. Warm Climate: Georgia’s mild climate means that you can enjoy outdoor activities year-round. The state has long, hot summers and mild winters, with average temperatures ranging from the mid-40s in January to the mid-80s in July.
4. Top-Ranked Universities: Georgia is home to several top-ranked universities, including the University of Georgia, Georgia Tech, and Emory University. These institutions offer world-class education and research opportunities.
5. Diverse Arts and Culture Scene: From the High Museum of Art in Atlanta to the Savannah Music Festival, Georgia has a thriving arts and culture scene. The state is also home to several historic sites, including Martin Luther King Jr.’s birthplace and the Ocmulgee National Monument.
6. Outdoor Recreation: Georgia is a paradise for outdoor enthusiasts, with miles of coastline, mountains, and forests to explore. The state has several national parks, including the Chattahoochee River National Recreation Area.
7. Southern Hospitality: Georgia is known for its friendly people and welcoming communities. Whether you’re in a small town or a big city, you’re likely to find people who are happy to help you feel at home.

These are just a few of the many reasons why moving to Georgia could be the right choice for you.

Local Attractions and Historical Locations

Georgia is a state that’s rich in history and culture, with plenty of local attractions and historical sites to explore. Whether you’re a history buff or simply enjoy learning about the past, Georgia has something for everyone.
One of the state’s most famous attractions is Stone Mountain Park, a massive granite outcropping that features a carving of Confederate leaders Robert E. Lee, Stonewall Jackson, and Jefferson Davis. The park also features hiking trails, a scenic railroad, and other outdoor activities.
Another must-visit destination is the city of Savannah, known for its charming historic district and Southern hospitality. Visitors can take a walking tour of the city’s cobblestone streets, visit the Bonaventure Cemetery, or take a riverboat cruise down the Savannah River.
For those interested in Civil War history, the city of Atlanta is a must-see. The Atlanta History Center features exhibits on the city’s role in the Civil War, as well as the civil rights movement. Visitors can also tour the Martin Luther King Jr. National Historic Site, which includes the civil rights leader’s birthplace, church, and tomb.
Georgia is also home to several historic plantations, including the famous Gone with the Wind plantation, Tara, which is now known as the Stately Oaks Plantation. Other plantations worth visiting include the Hofwyl-Broadfield Plantation, the Bulloch Hall, and the Roswell King Mansion.
For outdoor enthusiasts, the state has plenty of natural attractions, including the Chattahoochee National Forest, Amicalola Falls State Park, and the Okefenokee Swamp. Beach lovers can head to Tybee Island or Jekyll Island for a relaxing day by the water.

Advice for Planning Your Move

Moving to a new state can be an exciting and challenging experience. Here are some tips to help you plan your move to Georgia:

1. Research the Area: Before you move to Georgia, it’s a good idea to research the area you’ll be living in. Learn about the local schools, healthcare providers, and other important amenities. You can also research the crime rate in the area to make sure you’re moving to a safe neighborhood.
2. Budget for Your Move: Moving can be expensive, so it’s important to budget for your move in advance. This may include the cost of hiring a moving company, renting a moving truck, or purchasing packing supplies. You should also factor in any additional expenses, such as storage costs or temporary housing.
3. Declutter Your Home: Moving is the perfect time to get rid of any items you no longer need. Go through your belongings and donate or sell anything you don’t want to take with you. This will not only save you money on moving costs, but it will also make your new home feel less cluttered.
4. Create a Moving Checklist: Moving involves a lot of tasks, so it’s important to create a checklist to stay organized. This should include tasks such as packing, notifying utility companies of your move, and updating your address with the post office.
5. Get Moving Quotes: If you’re planning on hiring a moving company, it’s important to get quotes from several different companies. This will allow you to compare prices and choose the company that best fits your needs and budget.
6. Consider Using a Moving Service: If you’re looking for a more affordable option for your move, consider using a moving service like Moving Truck Driver. This service specializes in driving U-Haul and Penske rental trucks for people looking to move, which can save you a lot of money compared to hiring a full-service moving company.

By following these tips, you can help ensure that your move to Georgia goes smoothly and stress-free.

Creating a Moving Checklist

Creating a moving checklist is an essential step in the moving process. It helps you stay organized and on track, so you don’t forget any important tasks. Here are some tips for creating a comprehensive moving checklist:

1. Start Early: The earlier you start creating your moving checklist, the better. Ideally, you should begin at least two months before your move date. This will give you plenty of time to complete all the necessary tasks without feeling rushed.
2. Break it Down: Creating a long, overwhelming list of tasks can be daunting. Instead, break your moving checklist down into manageable chunks. For example, you could create separate sections for packing, notifying utility companies, and updating your address.
3. Be Specific: When creating your checklist, be as specific as possible. Instead of simply writing “pack,” break it down into specific tasks like “pack books,” “pack dishes,” and “pack clothes.” This will help you stay focused and ensure that everything gets packed properly.
4. Prioritize Tasks: Not all tasks on your moving checklist are created equal. Prioritize the most important tasks first, such as booking a moving truck or notifying your landlord of your move. This will help ensure that you get the most important tasks done first, and avoid last-minute panic.
5. Set Deadlines: To keep yourself on track, set deadlines for each task on your moving checklist. This will help you stay motivated and ensure that you’re making progress toward your move date.
6. Get Help: Moving can be overwhelming, so don’t be afraid to ask for help. Enlist family members or friends to help you with packing and other tasks. You can also consider hiring a professional packing service to help you get the job done.

Researching Your New Neighborhood

Researching your new neighborhood is an important step when moving to Georgia. Here are some tips to help you research and get to know your new community:

1. Look Up Local Amenities: Start by researching local amenities like schools, healthcare providers, grocery stores, and public transportation. This will give you an idea of what’s available in the area and help you plan your move accordingly.
2. Check Out Local Events: Check out the local calendar of events to get a sense of the community’s culture and activities. This can also be a great way to meet new people and make connections in your new community.
3. Learn About the History: Georgia has a rich history, and learning about it can help you appreciate your new home. Research local historical sites and landmarks, and plan to visit them once you arrive.
4. Check Crime Rates: No one wants to move to an unsafe neighborhood. Research the crime rates in your new community to make sure you’re moving to a safe area.
5. Join Local Facebook Groups: Joining local Facebook groups can be a great way to connect with other residents and get a sense of what life is like in your new neighborhood. You can ask for recommendations on everything from restaurants to dentists and get a sense of the community’s vibe.
6. Visit Your New Community: If possible, plan a visit to your new community before your move. This will give you a chance to explore the area and get a feel for what it’s like to live there.

By following these tips, you can get to know your new community and ensure that you’re making an informed decision about where to live in Georgia.

Conclusion

In conclusion, moving to Georgia can be an exciting adventure, but it can also be a stressful process. By following the tips outlined in this article, you can make moving to Georgia as smooth and stress-free as possible.
Start by creating a comprehensive moving checklist and breaking down your tasks into manageable chunks. Prioritize your most important tasks and set deadlines to keep yourself on track. Research your new neighborhood and get to know the local amenities, events, and history. Join local Facebook groups to connect with other residents and get a sense of what life is like in your new community.
When it comes to finding housing, consider using a reputable moving service like Moving Truck Driver, which specializes in driving U-Haul and Penske rental trucks for people looking to move. This can help you streamline the moving process and make your transition to your new home in Georgia as smooth as possible.
In conclusion, by taking the time to plan and prepare for your move to Georgia, you can ensure that you’re making an informed decision about where to live and that your move is as stress-free as possible. Good luck with your move, and welcome to Georgia!

I tried it for the first time today.
It took me like 25 min to go from 37 miles to 220. not quite 200 miles in 15 min but I assume its because LFP? I have a 23 m3sr. Also cost me $16 in NJ. kind of high?
I compared it to a ford maverick which gets about 40mpg and at $3.50/gallon its a similar rate but obviously fills much faster.
I mostly charge for free at work, but thought it was interesting.

In pretty much every anime ive seen based in high school be it fantasy, sci fi, or based in realism, the characters all seem to have easy access to the roof to have conversations about whatever they’re doing.
Is this a thing in japan? Are kids able to just go to their roof and chill out or is it really exaggerated?

Of the foreign diplomats you’ve met, especially from developed countries, do they consider American postings to be very desirable?
Obviously the America is a developed country, and we aren’t a hardship post by any regards. That being said, I can think of a few reasons why foreign diplomats might not prefer US postings, at least not as much as other developed nation posts.

• Lack of decent public transit outside of Ny and DC (and even DC public transit isn’t that great TBH), and I’m sure a significant portion of diplomats and their spouses can’t drive.
  
• US core cities (outside of NYC) have significantly higher crime, worse schools (if you need to go public), and urban blight than those in other comparable countries. So you’re stuck between living in downtown Los Angeles, Atlanta, or Houston (And can’t live further, cause no public transit, see part 1)
  
• with how strong the US dollar is, their foreign stipend doesn’t go far. A 5000$ stipend goes way further in London, Sydney, Singapore, and Ottawa compared to NY and DC
  
• none of the advantages of the US really are advantages to diplomats (Multicultural and welcoming society - diplomates aren’t here permanently ; high private sector salaries and business opportunities- again, they are government employees)
  

If the government mandates all roofs and roads must be relective white would that not cut down the heat island effect?
Roads and dense urban areas collect heat because everything is black or dark and absorbs the sun so instead we make everything white (high albedo) to relect the heat back into space. It could be a special paint thats polarizing or applied a certain way to intelligently redirect sun light and not into peoples eyes.
If they switched roads from asphalt to a permeanable white resin advanced polymer material it would also last longer and help with drainage and flooding- plus its white like pvc so it wont absorb heat as much as black tar and asphalt. It could be sprayed on existing roads or dirt roads
Think about how much oil is needed for all the asphalt roads redone every year. It doesn't last long and it hasn't been improved on for 100 years. Its time to upgrade the roads and while were at it lets add solar and wireless charging to the spray on permeable white polymer roadway with solar cells
Why wont this help?

Looking for a club? Come join Strange Clouds FC on PS5. We play most nights and have an active discord for eventsHow Experienced are we? Most of us have been playing together in a D1 club 250+ games.
STYLE OF PLAY: Our playing style is heavily influenced by the renowned Dutch Total Football philosophy, which emphasizes fluidity, creativity, and versatility. We strive to seamlessly transition between positions, allowing our players to fulfill multiple roles and maintain a high level of tactical flexibility. This approach ensures that we can adapt to various game situations, exploit spaces, and maintain a cohesive unit on the virtual pitch.
In addition to the Dutch Total Football influence, our playing style also incorporates elements of the legendary Italian football of the late 90s and early 2000s. During this era, Italian teams were known for their disciplined defending, meticulous tactical planning, and effective counterattacks. We employ these principles to maintain a solid defensive structure while capitalizing on swift and incisive attacks to catch our opponents off guard.
Combining the best of Dutch and Italian football, our Pro Club embodies a unique blend of creativity, teamwork, and strategic prowess. Our success lies in our ability to dominate possession, create scoring opportunities through intricate passing movements, and defend with resilience and organization.
How often do we play? we usually will run games 3-4 nights a week playing divs and friendlies. We will try to do 1-2 Tournaments a week as well. Usually start filling the lobby around 8:00pm CST
What formation do we play? We typically try to run 4-3-3 if we have the right players, we also will run 3-5-2
What positions are we looking for? We are looking for solid CB and Gk but openly recruiting for all positions
We will have trials at 8:30 and tournament at 930CST
DM if interested

Free shipping over $45, or $4 via USPS first class

Decants

House	Fragrance	6ml Price
By Kilian	Sacred Wood	$25
Creed	Aventus '21	$15
Creed	Millesime Imperial '17	$18
Creed	Bois Du Portugal '13	$22
Creed	Green Irish Tweed '16	$18
Creed	Tabarome Millesime '14	$16
Creed	Virgin Island Water '15	$22
Creed	Royal Water '12	$19
Creed	Erolfa '14	$20
Kerosene	R'Oud Elements	$15
Keroseme	Winter of 99	$15
Louis Vuitton	Imagination	$20
Memo	Russian Leather	$13
Tom Ford	Lost Cherry	$24
Tom Ford	Tobacco Vanille	$19
Thomas Kosmala	No. 4	$13
Vilheim Parfumerie	Morning Chess	$16
Xerjoff	Richwood	$24
Xerjoff	Alexandria Orientale (UAE Exclusive)	$26

All decants come in high quality, thick glass 3ml, 6ml, or 10ml atomizers with nice labels. All prices aren't listed to keep the post less cluttered. Message for specific 4 or 10ml prices. I guarantee all of these are 100% authentic. US only. Zelle/Paypal payment. Will ship within 48 hours!
Pic: https://m.imgur.com/a/4EbpDeb

I am considering filing a lawsuit I wrote. Do you think this has merit?
The Plaintiff is the proprietor of two businesses, namely [*], which is an electronic repair service, and [], an online retail business. Both of these businesses have a physical presence in [***].
In early 2020, the outbreak of the COVID-19 pandemic triggered unprecedented economic disruptions globally. Both of Plaintiff’s businesses, [*] and [*], were heavily impacted by these disruptions and faced severe financial setbacks.
Given the distressing circumstances, the Plaintiff, in his capacity as a small business owner, applied for two separate EIDL loans under the provisions of the CARES Act in order to offset the economic hardships caused by the pandemic. It is important to note that the Small Business Administration (SBA) is responsible for the implementation and administration of these provisions.
On June 8, 2020, the Plaintiff received a notification from the SBA, stating that the EIDL application for [****] had been approved. This approval entailed an Advance Grant amounting to $1,000.00 and an EIDL loan amounting to $1,500.00.
On June 16, 2020, the Plaintiff entered into an agreement with the SBA by signing the Loan Authorization and Agreement (LA&A) contract. Subsequently, on June 18, 2020, the SBA transferred the EIDL loan amount of $1,500 into the Plaintiff's personal bank account.
On June 25, 2020, the SBA initiated the transfer of the Advance Grant of $1,000.00 to the Plaintiff's personal bank account. However, this transfer was not successful and was returned to the SBA by the bank.
On June 26, 2020, the Plaintiff was informed via an email from his bank that the deposit of $1,000.00 made by the SBA had been returned to the depositor. The bank attributed this reversal to a discrepancy between the name on the deposit and the name registered on the bank account. This happened despite the successful deposit of the EIDL loan amount on June 18, 2020, indicating an error from the SBA's end as no changes were made to the account details by the Plaintiff. Over the course of the two years, the Plaintiff repeatedly reached out to the SBA for a resolution to this problem, but his pleas fell on deaf ears.
Contrary to the treatment of the application of [*], the EIDL application for [*] was denied by the SBA. Plaintiff received the denial notification on July 6, 2020, Plaintiff received an email From the SBA which contained a decline letter which stated, "Unfortunately, although we have made every effort to approve your loan request, we are unable to offer you a Economic Injury Disaster Loan (EIDL) for the reason(s) described below. Not Eligible: The SBA has been unable to verify the existence of an eligible business as reflected in the application. The SBA has been unsuccessful in our attempts to obtain documentation from multiple sources (public records) and we attempted to obtain documentation from you that would validate the existence of your business." Plaintiff disputes the SBA's claim to have "attempted to obtain documentation" from the plaintiff. The only time the SBA had reached out prior to the decline letter was On July 2, 2020, Plaintiff received a voicemail from the SBA asking Plaintiff to select a loan amount and submit for final approval.
On July 21, 2020, the plaintiff initiated contact with the SBA regarding the returned grant and the declined EIDL appliction. In a conversation with SBA Disaster Customer Service Representative Rossana M. Nuno, she explained her inability to provide case-specific advice or information. Instead, she could only offer general information about the program. The Plaintiff was informed that due to the depletion of funds, the Advance program had been terminated on July 13, 2020. The money that had initially been allocated to the Plaintiff for the Advanced Grant was no longer available. Plaintiff contended that this was a failure on the part of the SBA, that they had made a mistake sending the deposit and that it was their fiduciary duty to correct it. Nuno promise to make a note of it and notify her supervisors of the issue. The plaintiff managed to update their bank account details during this conversation in hopes that further errors would be avoided, and Nuno instructed the plaintiff to reach out to the Reconsideration Department for inquiries about the declined application and potential adjustments to the existing loan agreement At this stage, the plaintiff emphasized to Nuno that the applications were for separate business entities. Further she emailed the reconsideration instructions to both business entities.
On October 6, 2020, the plaintiff sent the first request for reconsideration letter to the SBA, attaching the documents as instructed by Nuno. The letter detailed the plaintiff's newness to business operations, the mistakes they'd made in financial and bookkeeping aspects, and the rectification of these errors. It also declared the filing of an Amended Tax Return for the years 2018 & 2019, which was still being processed by the IRS. The plaintiff included various supporting documents, including Business Bank information, State Identification, Driver's license, Social Security Card, Business registration with the Oregon Secretary of State, and IRS Form SS-4 assigning the business an EIN.
The SBA began a cycle of communication with the plaintiff from October 13, 2020, often requesting documents already submitted or requiring additional ones. Despite providing the necessary paperwork such as tax returns, Form 4506-T, and proof of identity, the SBA seemed to overlook the prior submissions and requested them repeatedly. This pattern continued until late December 2020, leading to significant frustration on the plaintiff's part.
On November 8, 2020, and several subsequent dates, the plaintiff sought to inquire about the status of their applications. However, these efforts yielded no responses from the SBA.
On January 7, 2021, the SBA responded with concerns about perceived discrepancies between the two applications, including different financials, number of employees, and Employer Identification Numbers (EINs), and the reported revenue. The plaintiff clarified that the applications were for two separate business entities with distinct financials, employees, and EINs. The plaintiff speculated that the SBA might have been misled by the similarity in trade names of the two businesses.
The plaintiff's dissatisfaction with the SBA's treatment escalated by March 2021. They composed a detailed letter of appeal on March 25, 2021, where they voiced their struggles, highlighted the separateness of the two businesses, and expressed their irritation with the SBA's repetitive requests for already provided documents. This letter also contained a plea for the SBA to take their case more seriously and to expedite the application process.
In a disappointing development on March 28, 2021, the SBA sent another email requesting more documentation. Many of the requested items were documents that the plaintiff had submitted multiple times in the past. Feeling helpless and dissatisfied with the SBA's handling of their case, the plaintiff turned to the office of U.S. Congress Member Kurt Schrader. They submitted a comprehensive summary of their ordeal, detailing the SBA's apparent disregard of their explanations, the repeated requests for documents, and their overall grievances with the SBA's treatment of their businesses.
On March 29, 2021, the plaintiff received an email from Alvin Klausen, a Field Representative from the Office of Congressman Kurt Schrader. In his email, Klausen requested further clarification on the issues at hand and asked for supporting documents to bolster the plaintiff's case.
The plaintiff also received a somewhat reassuring email from Vanessa R., an SBA Customer Service Center Representative, acknowledging receipt of the plaintiff's documentation. She stated, "We have notated the file with the information provided. We forwarded your email and attachment(s) to our Processing and Disbursement Center for review and file association." Even so, the SBA continued to ask for documentation that they had already received.
Two days later, on March 31, 2021, the plaintiff sent another email to Alvin Klausen, this time detailing their grievances against the SBA. The email was a passionate plea for recognition and change, highlighting several key issues. These included perceived discrimination by the SBA against the smallest businesses, a 'delay and deny' tactic used by the SBA, and repeated requests for duplicate information that were both tiresome and confusing. The plaintiff also questioned the SBA's ability to manage information and records effectively, attributing their struggles to the organization's mismanagement. They expressed a desire for accountability and reform, making it clear that while they wanted their personal issues addressed, they also hoped for broader changes within the SBA to benefit all small businesses.
On April 3, 2021, the plaintiff was taken aback by an email from the SBA, which stated, "We have received multiple applications from your business for economic injury as a result of Coronavirus (COVID-19). Your earliest application will continue to be processed, and we have withdrawn application number *****1116 from active consideration." The plaintiff felt this statement was fundamentally incorrect, as they had applied for two distinct businesses, each with separate financials, employees, and EINs. They reiterated that both businesses were in operation before January 1st, 2020, and both had suffered economic injury due to Covid-19. The plaintiff insisted that according to the CARES Act, both applications were valid and deserving of consideration.
A promising development occurred on April 7, 2021, when the plaintiff received an email from Alvin Klausen, stating that a Congressional inquiry had been submitted on their behalf. This offered a glimmer of hope, indicating that their struggle was gaining attention at higher levels and might lead to some resolution.
On April 13, 2021, a communication came from the Small Business Administration (SBA) Loan Officer, Ayesha Babar. She requested additional supporting documents for the plaintiff's application, explicitly mentioning the application number *****0742. The language in the email underscored the urgent necessity for the plaintiff to complete a particular form, with a clear warning: failure to provide the requested Form 4506-T within a week could lead to denial of the plaintiff's aid request. This gave rise to questions about the SBA's policies, especially whether this time-constrained requirement was a standard SBA policy or the discretion of an individual loan officer.
Just a day later, on April 14, 2021, another email from Babar arrived. It sought further information to move forward with the loan modification process and, importantly, put forth a request for immediate communication, either via a phone call or an email response. The email contained an explicit timeline: a response was needed within two days, or else the plaintiff's request could be labeled as 'not interested'.
These interactions highlight the SBA's conduct, characterized by an exigency that seemed to border on the arbitrary, as per the plaintiff's perspective. From a seven-day deadline for document submission to a two-day ultimatum for a call-back, the SBA's approach was perceived as a high-pressure tactic. This conduct raised serious questions about the equitable treatment of loan applicants and the management of relief funds intended to support small businesses during the pandemic.
On April 15, 2021, the plaintiff was contacted via email by Anna Rose, an SBA Loan Specialist, who was appointed as an advocate for the plaintiff's case. Rose expressed her intention to address the plaintiff's increase request and suggested a direct phone conversation for further clarification on the outstanding issues.
A telephonic conversation between the plaintiff and Rose took place the same day, during which the plaintiff articulated the hurdles encountered in the reconsideration process. Rose admitted she hadn't previously reviewed the plaintiff's provided documentation or any prior emails related to the case, though she was aware of the congressional inquiry initiated on the plaintiff's behalf.
Throughout the discussion, the plaintiff reiterated multiple points, clarified the nature of their "Qualified Joint Venture" tax status as opposed to a 1065 Partnership, highlighted the separation of business entities, and raised several issues previously discussed with the SBA. The issue of the missing Advance Grant portion was frequently brought up by the plaintiff. Although Rose acknowledged this concern, she clarified her lack of involvement in the advance program and asked the plaintiff to be patient.
Rose, in her capacity as advocate, took on an advisory role, guiding the plaintiff through the process, and requesting various supporting documents, including the original 2019 Federal Tax Return, SBA Form 2202 Schedule of Liabilities, IRS Tax Form 4506-T, and a Partnership Agreement. The SBA appeared to be in a thorough review phase, trying to ensure that all the necessary documentation was in order.
A significant aspect of these interactions was the decision to request an updated 2019 Tax Transcript from the IRS. Rose, on April 20, 2021, indicated that the utilization of the amended tax return figures (as opposed to the original ones) could lead to a larger loan amount for the plaintiff. However, this move, framed by Rose as the goal, was made without explicitly providing the plaintiff an opportunity to make an informed decision or explaining the implications of such a request. It was clear that the objective of leveraging the amended tax return for a higher loan amount was initiated by the SBA, specifically Rose, and not the plaintiff. This suggests an attempt by the SBA to maximize the available support for the plaintiff, albeit with a lack of transparency in communicating the possible consequences and constraints.
As the discussions between the plaintiff and SBA Loan Specialist Anna Rose progressed in April and May 2021, the focus remained on the plaintiff's amended tax return and the corresponding IRS transcripts, pivotal elements in the loan reconsideration process. In these communications, Anna Rose called for the submission of multiple forms, including IRS Form 4506-T.
A crucial point arose on May 6th, 2021 when Rose falsely reported to the Plaintiff that the IRS hadn't processed the plaintiff's amended tax return. This assertion was in direct contradiction to the plaintiff's records showing the return's adjustment, finalization, and subsequent payment.
Furthermore, when the SBA received Plaintiffs tax transcripts on April 23, 2021, and May 3, 2021, they both showed that the tax return had been processed. This fact was withheld by the SBA and kept from the Plaintiff. It would only be revealed in the Freedom of Information Act Request that Plaintiff acquired in 2022.
Rose then suggested that the plaintiff wait for the processing of the amended tax return before incorporating the amended gross revenue numbers. Plaintiff is told by Rose, "you can wait a couple of months until the amended tax return has been processed. This is the only way we will be able to go off of the AMENDED gross revenue." Plaintiff is told this despite having satisfied the requirements as stated by Rose on April 20, 2021, "This transcript should show that an AMENDED RETURN was filed. That's all the information that I need in order to use your AMENDED Tax Return figures."
Most notably, Rose informed the plaintiff of a policy that limits the resubmission of Form 4506-T to every 60 days or a couple of months. However, neither the SBA nor the IRS has an established policy restricting the submission of Form 4506-T to every 60 days. This alleged policy seems inconsistent with the Covid Relief Acts' guidelines and raises questions about its applicability and fairness. As a result, the invocation of this policy by Rose marks a significant point of contention in the loan modification process with the SBA.
On May 7, 2021, the plaintiff forwarded a screenshot from the IRS website confirming the completion of their tax amendment and questioned whether this would influence the decision.
Ten days later, on May 17th, 2021, despite the plaintiff's evidence, Rose indicated that the agency lacked confirmation that the plaintiff's amended tax return had been processed. The transcript's absence resulted in a significant discrepancy in potential loan amounts based on the reported gross revenue. Rose restated the need to wait 60 days from May 6, 2021, before reordering the tax transcripts.
The next day, the plaintiff was informed by Rose that their file had been forwarded to another department for assistance with the requested increase. This abrupt transition was given without detailed explanation, leaving the plaintiff uncertain about the next steps in the process. In response, the plaintiff voiced their frustration and confusion over the lack of clarity, and the perceived lack of assistance from the SBA.
Finally, Rose clarified that the plaintiff's file had been forwarded to the funding department to handle the increase request, citing that she had no control over this change. For any queries related to the advance funds, she directed the plaintiff to the customer service department.
On May 25, 2021, SBA Loan Specialist Austin Ross communicated with the plaintiff via email, requesting further details about the partnership filing status on the recently amended Federal Tax Return. Ross specifically states that the loan modification could not be processed until there was clarification of his business's 1065 partnership tax status. This was despite the plaintiff having shared this information multiple times in prior communications with various SBA representatives.
In response, the plaintiff reiterated the pertinent details to Ross and sought a definitive list of remaining requirements to finalize the aid request. A phone conversation between the two provided an opportunity for the plaintiff to clarify multiple points around the amended tax return, the nature of the “Qualified Joint Venture” tax status as opposed to a 1065 partnership, separation of business entities and ownership, the completion of the tax return, among other issues.
Following this conversation, Ross sent a summary email presenting two courses of action: waiting for the IRS to process the updated tax transcripts or proceeding based on the existing application details. However, discrepancies arose in Ross' recounting of the conversation, primarily concerning the waiting period for tax transcripts, the establishment of a loan modification, and the plaintiff's interest in the Targeted Advance program. Contrary to the plaintiff's stated intent to proceed correctly with the loan process and accept a loan amount commensurate to their qualifications, Ross miscommunicated this as the plaintiff preferring to wait for the updated tax transcripts due to potential differences in loan amounts.
Additionally, Ross indicated that the SBA could create a loan modification based on the existing application data, while the SBA subsequently sent a decline letter for the loan modification on June 12, 2021. Moreover, Ross's assertion that the plaintiff showed interest in applying for the Targeted Advance program misconstrued the plaintiff's wish to address the issue of the returned EIDL grant.
In closing his email, Ross expressed enthusiasm to continue working with the plaintiff, but his actions did not align with these words. The plaintiff's subsequent attempts to reach Ross through phone calls, messages, and emails went unanswered. Over a period of the next three months plaintiff would call and email Ross multiple times only to be completely ignored by Ross. This pattern of discrepancies between Ross's written statements and the actual actions of the SBA amplified the plaintiff's frustration and perceived mismanagement of their case by the SBA.
On May 28, 2021,the plaintiff received a communication from SBA Loan Specialist Dave Dubois, demanding additional documentation that didn't pertain to the nature of the plaintiff's business. These included requests for proof of an active insurance policy and board resolution providing authorization for the loan. These requests were glaringly irrelevant, considering the plaintiff operated without a board of directors and did not require an insurance policy to conduct his business. This demonstrates an apparent lack of understanding or consideration of the plaintiff's business model by the SBA.
A significant development occurred on June 12, 2021, when the plaintiff received an email from the SBA, attached with a letter dated April 3, 2021, stating that his request for a loan modification had been declined due to "Unverifiable Information." The letter claimed that during the loan underwriting process, the SBA encountered issues with the validity of some of the information the plaintiff submitted. The plaintiff was particularly perplexed because the decision to decline the loan modification was apparently made on April 3, 2021, but was only communicated to the plaintiff over two months later, exposing an egregious delay of more than two months in the SBA's communication. This decision predates the assignment of SBA Loan Specialist Anna Rose as the plaintiff's case advocate.
Seeking clarification, on June 24, 2021, the plaintiff emailed SBA Loan Specialist Austin Ross, attaching the SBA decline letter and the letter from Dave Dubois, and asked for an update on his loan modification status. However, this attempt to gain insights into his application status was also met with silence; Ross never responded to the plaintiff's inquiry. This further highlights the communication inconsistencies and lack of transparency in the handling of the plaintiff's case by the SBA.
These events draw a critical spotlight on the SBA's handling of the plaintiff's case, particularly emphasizing the disconnect in communication, a failure to comprehend the business's nature, the delayed disclosure of vital decisions, and a persistent lack of response from SBA representative Austin Ross.
On June 24, 2021, the plantiff made an attempt to resolve the ongoing loan modification issues by reaching out to multiple SBA representatives, including SBA Loan Specialist Anna Rose. Rose's response, however, was perplexing. Despite her role, she expressed unawareness of the decline letter and shifted responsibility, putting the onus on the plaintiff for not accepting a purported loan increase — an offer that, to the plaintiff's knowledge, had never been formally made.
Most importantly, Rose laid down stringent requirements, instructing the plaintiff to provide a fully processed and IRS-stamped amended tax return along with an updated and signed 4506-T form, underscoring the red tape marring the SBA's process. Furthermore, Rose highlighted that 60 days had passed since the last transcript was received, implying that the plaintiff needed to hasten his interaction with the IRS — another burden imposed on the plaintiff.
The SBA on July 1, 2021 reiterated the loan decline decision — a decision made three months prior on April 3, 2021, but uncommunicated until June 12.
In response to the array of impediments, the plaintiff kept pushing forward, providing the requested IRS transcript to Rose on July 21 and formally objecting to the decline on July 22. This well-articulated objection included necessary documentation, a fresh IRS Form 4506-T, and a specific request to move forward with the loan modification.
Throughout this convoluted process, the SBA, particularly through the actions of Rose and Ross, demonstrated an alarming level of inefficiency, bureaucratic entanglement, and unresponsiveness. The persistent silence, stringent requirements, lack of clear communication, and the controversial 60-day waiting policy before resubmitting a 4506-T form, critically marred the plaintiff's journey with the SBA, ultimately reflecting poorly on the agency's commitment to aiding small businesses.
On July 26, 2021, a detailed account of the ongoing issues was provided to Alvin Klausen, a liaison from Congressman Kurt Schrader's office, and copies were sent to SBA Loan Specialists, Anna Rose and Austin Ross. However, it seemed this attempt at gaining resolution bore no fruitful response.
In further compliance with SBA's requirements, the plaintiff sent to Anna Rose on July 31, 2021, a range of documents including an IRS-stamped Form 1040X, an IRS-printed Account Transcript, and a completed IRS Form 4506-T. This move was in response to Rose's instruction from June 24, 2021, yet there was no acknowledgement or meaningful reply.
Persisting with the process, the plaintiff dispatched exhaustive document packages to the SBA via fax on July 30 and July 31. Despite containing all necessary material to overcome the loan decline, these emails seemed to fall into a void, receiving no response.
The plaintiff took a crucial step on July 31, 2021. A detailed complaint was submitted to the Small Business Administration Office of the National Ombudsman. This report illuminated the interactions between the plaintiff, Ross, and Rose, and presented an extensive analysis of the challenges the plaintiff was encountering. Yet, in the ongoing pattern of silence, the plaintiff received no follow-up or response to this complaint.
The communication gap continued as on August 3rd, 2021, the SBA reiterated the decline reason, citing a lack of verifiable information, while ignoring the submitted IRS-stamped documents. The plaintiff tried to overcome this by sending an objection email with additional IRS documentation on August 6th, 2021, yet there was no indication of SBA's receipt or review of this new information.
On September 9th, 2021 the SBA requested 2019 business bank statements. This was curious as the SBA bypassed the essential step of ordering the IRS transcripts using the 4506-T. Moreover, it neglected to consider that the plaintiff didn't have a business bank account in 2019 and relied on online payment processors like PayPal and Amazon Pay for business transactions.
The plaintiff expressed their frustrations and disappointment in a response on September 14th, 2021. This correspondence conveyed the sentiment of being systematically ignored, manipulated, and deceived by the SBA. The plaintiff's concerns about the agency's lack of intent to provide assistance and the perceived injustices were made clear. Despite their efforts, the plaintiff was left in a seemingly endless loop of unmet requirements and unanswered queries.
In the subsequent months, the plaintiff did not receive any further information or correspondence from the SBA concerning their loan modification request, causing additional distress. The plaintiff expressed their frustration and disappointment with the entire process in an email to the SBA, stating that the constant silence and lack of feedback from the SBA were indicative of gross negligence and a breach of the SBA's fiduciary duties.
On July 31, 2021, initiated a fresh application for their sole proprietorship, [*], heeding the guidance of SBA Loan Specialist Austin Ross. It is essential to underscore here that Ross, in his advisory role, inadvertently mischaracterized [] as a cellphone repair business. However, [***] is an online retail business. Another example of Ross's blaintaint inaccuracies.
This effort was met with a contradictory response. The plaintiff was informed that their reapplication had been withdrawn due to it being a duplicate application. Then in an abrupt about-face, the SBA invited the plaintiff to proceed with the withdrawn application, issuing successive reminders about completing the application process.
Despite reservations about the sincerity of the offer, the plaintiff accepted the proposed loan amount. True to their suspicion, a decline letter arrived on October 22nd, 2021, citing the inability to verify the existence of an eligible business.
On January 3, 2022, the Plaintiff sent an email to the SBA asking to address the $1,000 advance grant that was returned June 25, 2020. The SBA responded with these instructions, "To assist in processing your request please reply to this email with: A copy of your photo identification (front and back), A copy of a check with the word "VOID" written on it (please do not redact the routing or account number) and, If you need to submit an updated 4506-T, the completed and signed corrected 4506-T form may then be sent as a reply to this email or may be emailed to [email protected]."
On January 10, 2022, the Plaintiff sent another email to the SBA with all the requested documents and expressing his frustration over the lack of resolution to his issue and the impacts it had on his eligibility for the targeted advance and the supplemental advance.
The SBA remained unresponsive and the status of the Advance on the SBA Disaster Portal was changed from "error" to "declined" without any explanation. This exclusion from the Advance Grant portion of the EIDL program, along with the Targeted Advance Grant and Supplemental Grant programs, was conducted without any legal justification.
For the record, it's important to note that the applicants must receive an official email invitation from the SBA to apply for both the Targeted EIDL Advance and Supplemental Targeted Advance. Due to the aforementioned error, the Plaintiff was deprived of this opportunity and thus, was unable to apply for these programs.
The SBA's failure to adequately process the deposit for the Advance Grant, coupled with their refusal to rectify the problem despite the Plaintiff's repeated attempts to seek a resolution, is a clear violation of their obligations. The repercussions of this error not only prevented the Plaintiff from receiving the Advance Grant but also from applying for the Targeted EIDL Advance and Supplemental Targeted Advance.
It is pertinent to highlight that these grants were crucial for the Plaintiff's businesses to mitigate the devastating financial impact of the COVID-19 pandemic. Thus, the failure of the SBA to fulfill its duties has caused substantial harm to the Plaintiff and his businesses.
Moreover, the lack of communication from the SBA and the subsequent change in the status of the Advance from "error" to "declined" without any given explanation is unacceptable. This behavior demonstrates a blatant disregard for the dire financial circumstances the Plaintiff found himself in due to the COVID-19 pandemic.
Not to be deterred, the plaintiff initiated a reconsideration request on March 1, 2022. In response, they were given a list of documents to submit, which they promptly did. Unfortunately, another decline letter soon followed, reiterating the inability to verify the business's existence.
The plaintiff sought a final reconsideration on April 2, 2022, asking for a comprehensive list of all requirements needed to overcome the stated reasons for decline. In a repetitive cycle, the SBA updated the application status on April 6, 2022, asking for a series of documents which, as per the plaintiff's account, had already been submitted numerous times.
Again the plaintiff submitted the required documents as per the updated request on the SBA Economic Injury Disaster Loan Portal account. Despite this, it's important to highlight the plaintiff's firm belief that the SBA was employing tactics of constant delay or denial regardless of the file status, even when all necessary documents were submitted, and all discrepancies were addressed legally. The plaintiff contends that such an approach seems to be a systemic internal policy, serving to deter applicants until the SBA could close the program. Unfortunately, the plaintiff's diligent efforts were met with an insurmountable roadblock when the SBA announced the exhaustion of all funds under the EIDL program. This, sadly, left the plaintiff's persistent attempts to secure the loan unfulfilled.
CAUSES OF ACTION
FIRST CAUSE OF ACTION: BREACH OF CONTRACT
The Plaintiff repeats, reiterates, and realleges each and every allegation contained in paragraphs 1 through ** as if fully set forth herein.
The Plaintiff entered into a contractual relationship with the SBA when it accepted the terms of the EIDL program, which was manifested by the approval of the EIDL advance grant and signing the Loan Authorization and Agreement (LA&A) contract.
The SBA had a contractual obligation to provide the approved advance grant to the Plaintiff as well as process the Plaintiff's requests in accordance with its established procedures and guidelines.
The SBA breached this contractual obligation by failing to deposit the approved advance grant, changing the status of the advance grant from "error" to "declined" without due justification, and failing to rectify this situation despite the Plaintiff's attempts to seek resolution.
As a direct result of the SBA's breach of contract, the Plaintiff suffered significant financial harm.
SECOND CAUSE OF ACTION: NEGLIGENCE
The Plaintiff repeats, reiterates, and realleges each and every allegation contained in paragraphs 1 through ** as if fully set forth herein.
The SBA owed Plaintiff a duty of care to diligently review and process EIDL applications, provide clear and consistent communication, provide adequate customer support, and demonstrate transparency in decision-making.
The SBA breached this duty by their actions as outlined above.
As a direct and proximate result of the SBA's negligence, Plaintiff has suffered damages, including but not limited to lost opportunities for financial relief and detrimental effects on the business, in an amount to be determined at trial.
THIRD CAUSE OF ACTION: MISREPRESENTATION
The Plaintiff repeats, reiterates, and realleges each and every allegation contained in paragraphs 1 through ** as if fully set forth herein.
The SBA made representations to the Plaintiff regarding the processing of the Plaintiff's application and the subsequent steps needed to rectify the situation.
These representations were false, as evidenced by the SBA's subsequent actions, which included changing the status of the Plaintiff's application without due justification and requesting documents that had already been submitted multiple times.
The Plaintiff, relying on these misrepresentations, suffered substantial financial harm.
FOURTH CAUSE OF ACTION: VIOLATION OF DUE PROCESS
The Plaintiff repeats, reiterates, and realleges each and every allegation contained in paragraphs 1 through ** as if fully set forth herein.
The SBA violated the Plaintiff's right to due process under the Fifth Amendment by declining the Plaintiff's application without providing any legal justification or opportunity to rectify the issue.
The SBA's actions, including unresponsiveness and failure to provide a fair reconsideration process, deprived the Plaintiff of the opportunity to adequately address the issues affecting his eligibility for the grant and loan.
FIFTH CAUSE OF ACTION: VIOLATION OF THE ADMINISTRATIVE PROCEDURES ACT (APA)
The Plaintiff repeats, reiterates, and realleges each and every allegation contained in paragraphs 1 through ** as if fully set forth herein.
The SBA, as an agency of the U.S. government, is subject to the APA, which requires federal agencies to follow certain procedures when making or changing rules.
The SBA violated the APA by acting arbitrarily and capriciously in its handling of the Plaintiff's application and its subsequent actions. This includes changing the status of the Plaintiff's grant without providing a reasoned explanation, unresponsiveness to the Plaintiff's attempts to seek resolution, and the failure to offer a fair reconsideration process in accordance with established rules and procedures.
Specifically, the SBA's refusal to rectify the erroneous deposit, even after being repeatedly informed by the Plaintiff, constitutes an arbitrary and capricious action under 5 U.S.C. § 706(2)(A). This statute allows courts to set aside agency actions that are arbitrary, capricious, or an abuse of discretion.
Furthermore, the SBA's failure to communicate effectively with the Plaintiff about the issue, followed by the unexplained change in the status of the Advance from "error" to "declined", are against the agency's obligation of providing 'reasoned explanation' for its decisions, a principle well established in the case law, see, e.g., Motor Vehicle Mfrs. Assn. v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983).
As a direct result of these violations, the Plaintiff suffered significant financial harm and a loss of opportunity to benefit from the EIDL program, the Targeted EIDL Advance, and the Supplemental Targeted Advance.
As such, the SBA's actions were in violation of the APA, and the Plaintiff is entitled to relief under the APA.