Magazine duped Vacaville into spending thousands on ads during pandemic, records show

A little-read business magazine called Comstock's used false information to convince the City of Vacaville and others into spending thousands of dollars on advertisements during the pandemic.

(Photo: A sign outside the former office of Comstock’s Magazine, a Sacramento-based business publication. File photo by Solano NewsNet.)

A few weeks after the global health pandemic forced businesses to close and workers to remain at home, the City of Vacaville and its partner agencies agreed to spend thousands of dollars in magazine advertisements promoting itself as a place to do business.

The advertisements ran in Comstock’s Magazine, a business publication that distributes just five copies of its magazine at a single retail store in Solano County and whose circulation and reach is substantially less than any individual newspaper or news website in the region.

For months, Comstock’s tried to woo city officials and workers at some of the city’s marketing partners into spending big money on its various advertisement products. While those discussions were underway, the magazine faced potential scrutiny for failing to adhere to federal advertising rules.

City officials were never told about the problem. Instead, Comstock’s promised to provide its freelance writers to craft stories that cast the City of Vacaville and its initiatives in a favorable light, with wide distribution in print and on social media. As long as they were willing to pay big bucks for the privilege.

The City of Vacaville, its not-for-profit marketing firm, and some local businesses agreed to do just that. Nearly two years later, some of what the City and its partners paid for has still not been delivered. And questions remain as to why the City of Vacaville would agree to spend thousands of dollars in advertising at a time when businesses were closed and residents were struggling due to the pandemic.

Earlier this year, Comstock’s learned this story was being produced. Editors at the magazine worked furiously to prevent it, going so far as to contact the Federal Bureau of Investigation and the U.S. Attorney’s Office in an effort to have the story stopped.


To understand how Comstock’s was able to convince city officials to part with a huge chunk of money in the middle of a pandemic, it is helpful to know the magazine got its start.

It was, apparently, divine intervention.

Before starting her own publication, Winnie Comstock-Carlson worked as an advertising executive for another regional magazine, a position she held until the late 1980s. She arrived to work one day to find the office doors locked.

A few weeks later, a “message from God” encouraged her to start her own magazine, she said in a 2015 interview. She launched the publication, asking vendors to wait for payment until advertising revenue began to trickle in.

It did. Companies like Radio Shack, Dell Computer and even local news radio station KFBK (1530 AM) were more than willing to buy advertisements in her magazine. For two decades, cash was easy to come by. Print was still in. The World Wide Web had yet to make a dent.

And then, all of a sudden, the Web was all anyone could talk about. Within a few years, companies shifted their spending from print advertising to digital — a trend that accelerated during the Great Recession. Google and Facebook were the largest benefactors, with their ability to microtarget consumers helping to grow their dominance in the advertising market; newspapers and magazine were the biggest victims.

Comstock-Carlson was not deterred. She quickly realized that, while businesses may be shifting their ad spend due to the financial crunch, local government agencies had plenty of cash on hand. She shifted the magazine’s focus accordingly and began offering free subscriptions to state lawmakers and local officials — a move that gave the magazine greater exposure in some key circles and kept it profitable for at least another five years.

The Great Recession should have been a wake-up call — a push for the company to finally embrace the new digital media landscape. But by 2011, its online presence still left a lot to be desired. Some employees at the magazine urged Comstock-Carlson to invest more in the digital space. Her response was to fire Doug Curley, the magazine’s editor of nearly 10 years, and elevate 31-year-old Christine Calvin to his position. She also hired Allison Joy, who worked at the alternative website Sacramento Press, to re-develop the Comstock’s website and invest in new digital initiatives.

Those promotions were largely symbolic: Comstock-Carlson wanted to give the appearance that the magazine was leaning into the digital space, but the company did little else to nurture that idea. Young staffers felt their ideas were ignored.

By 2015, the company began to lose workers. One year later, Calvin quit and was replaced by Joy. In 2019, Joy resigned, telling colleagues she felt burned out and needed a change of pace (when she quit, the company had just eight full-time workers).

The company’s finances were also in dire straights. By the middle of the 2010s, even government agencies had started shifting their advertising interest away from print and toward digital. Undeterred, Comstock’s decided to employ a new tactic: It would replace a philanthropic initiative called “Comstock’s Cares” and produce so-called “special sections” — advertisements that are designed to look like journalism — on behalf of local cities and government agencies.

To convince government agencies to keep advertising, Comstock’s decided to make itself look bigger and more-influential than it actually was.


In late 2018, Comstock’s began formulating plans for its special sections initiative. The first step was figuring out how much to charge for it; the harder part was convincing a city official to lobby for what was essentially an untested idea.

Comstock’s found its ally in Michael Jasso, an assistant city manager with the City of Sacramento. Editors told Jasso their idea: The magazine would set aside around 30 pages in its print edition for advertisements focused exclusively on Sacramento agencies, businesses and initiatives. Some of those ads were traditional, but some would look like journalism — except, in this case, writers would work hand-in-hand with the City of Sacramento and other stakeholders to cast their initiatives in a positive light.

The concept was not new: For several years, newspapers, news websites and other magazines had produced “sponsored content” that took the same form. But in most cases, those stories were a one-off. Here, Comstock’s was proposing an entire section made up of several stories, for which the City of Sacramento and its advertising partners would have absolute control.

That caught Jasso’s attention, and he committed to the idea. In March 2019, Jasso wrote a letter to other agencies and local businesses urging them to get on board. In his letter, he wrote that the magazine reached “an audience of more than 85,000 key business executives and public officials.” The letter did not include any information that supported that figure.

That figure would later be repeated by Timothy Padden, who worked in an economic development role with the City of Sacramento before joining the City of Vacaville in July 2019. His influence would become key later on when Vacaville agreed to a special section of its own the following year.

Comstock’s began lobbying the City of Vacaville for its own special section in November 2019. In an e-mail obtained by Solano NewsNet, Comstock-Carlson herself pitched the idea to Melyssa Reeves (then Melyssa Laughlin), the chief executive of Visit Vacaville, a not-for-profit marketing agency that promotes the city in partnership with its local government and other groups.

Comstock-Carlson provided Laughlin a copy of Jasso’s letter. It caught her attention: Visit Vacaville was always looking for creative ways to promote its local businesses and city initiatives. Getting in front of 85,000 politicians, business leaders and other key stakeholders seemed like an opportunity that was too good to be true.

It was, according to records reviewed by Solano NewsNet along with information provided by current and former employees, which showed the magazine was greatly exaggerating the number of people its news and advertisements got in front of.

The records show Comstock’s printed an average of 1,500 magazines each month, with around 200 of those magazines intended for retailers who agreed to sell each edition for around $5. In Solano County, only one retailer — the Nugget Supermarket in Vacaville — carries Comstock’s, with its inventory limited to just five copies per month (most months, the supermarket returns all five copies after they fail to sell).

Around 500 copies per issue are retained by Comstock’s for its own internal use, including distribution to advertisers, while the rest are distributed by mail to subscribers.

The company’s online presence is no better: Internal data from 2018 supplied by a former editor and reviewed by Solano NewsNet showed the company accrued less than 5,000 unique page views per month — far less than the websites of most small newspapers. A digital version of the print publication is available to download; it has less than 100 subscribers, and few of them bother to download the magazine each month.

On social media, the company appears to have thousands of followers, but a former Comstock’s marketer who spoke with Solano NewsNet on condition of anonymity said the company achieved those numbers by paying for a service that artificially inflated its follower counts on Instagram, Facebook and Twitter (an independent audit found many of its social media audience were robots; the company stopped paying for the service in early 2019, the employee said). An e-mail newsletter sent to some digital subscribers has a mailing list of around 5,000 addresses, but fewer than 100 recipients actually open those mailings, the employee said.

All told, the company’s reach is far fewer than the 85,000 business leaders and professions that Comstock’s claimed in its pitches to the City of Sacramento, one that was repeated by Visit Vacaville when it lobbied on behalf of the magazine. In an e-mail sent to Solano NewsNet in February, Reeves acknowledged Visit Vacaville had no way to prove what Comstock’s was claiming.

“We take the information provided from the publications at face value, as we have no way to prove or disprove,” Reeves wrote. “I was provided a sales sheet with distribution and circulation data.”

Despite having nothing to show for its accuracy, Reeves passed the information on in her own pitches to city officials and local businesses. E-mail records obtained by Solano NewsNet show then-City Manager Jeremy Craig was one of the people included in those conversations. Later, his replacement, Aaron Busch, was included as well.

That information was passed along to several community stakeholders, including officials within the City of Vacaville. At one point, then-city manager Jeremy Craig was included in those conversations. His replacement, Aaron Busch, was also approached.

But Padden was the key to securing the deal for Comstock’s. He remembered getting Jasso’s letter during his time with the City of Sacramento, and he was immediately drawn to the idea.

Another person who held a significant amount of influence was Robert Burris, who then worked as the chief executive of the Solano Economic Development Corporation, a key economic partner for the City of Vacaville. Before he was even approached by Reeves, Burris had a keen awareness of Comstock’s: He served on its editorial advisory board and regularly attended a bi-monthly meeting at an upscale restaurant where Comstock’s always paid for his meal.

It isn’t clear from conversations produced to Solano NewsNet if Burris ever disclosed his connection with the magazine. But his support was a large reason why Visit Vacaville and the City of Vacaville decided to take Comstock’s up on his offer.

“Tim Padden,…Bob Burris and I met today to discuss, and we are all committed to making this happen,” Reeves wrote in an email to Comstock-Carlson in early December.

Two days later, Comstock-Carlson replied, outlining how the special section would come together: Comstock’s would do “all the writing, design and production” and coordinate meetings with Reeves, Burris, Padden and others to discuss the types of stories that would be written. Those stories “would be developed with input and sources provided by you, Bob and Tim,” and Comstock-Carlson promised that the full resources of the magazine’s editorial team — which also had to work on its journalism — would be at the City’s disposal.

In exchange, the City of Vacaville had to commit to “a minimum of two pages in the section,” with that space reserved for traditional advertising. Later, Comstock’s said the City could purchase an option to have the same section placed on the Comstock’s website “so it can be digitally used as a marketing tool.”

The City also had to produce a list of companies that Comstock’s could approach for additional advertising opportunities. Along with the list, Comstock’s required someone at the City to produce an endorsement letter on the magazine’s behalf.

“It would be very helpful if you send that endorsement letter out to likely advertising prospects separately, so they know we’ll be in touch and that we’re doing this in partnership with you,” Comstock-Carlson wrote in an e-mail obtained by Solano NewsNet.

The responsibility of creating the list and writing the letter fell to Padden. In January, he sent the list to Reeves, who approved it and suggested the inclusion of other companies. The list included radio station KUIC-FM, biotech firm Genentech, Travis Credit Union and Solano Community College.

Padden also wrote an endorsement letter of his own, where he repeated much of what his former colleague said, including the unsubstantiated claim that Comstock’s reached “more than 85,000 key business executives and public officials.”

“As a partner of Comstock’s Magazine, we invite you to seriously consider this opportunity to highlight your products and services and to spotlight forthcoming projects in the growing Vacaville and Solano County community,” Padden wrote in his letter, which was produced using stationery bearing the City of Vacaville seal.

None of the companies on Padden’s list ultimately advertised in the section. But the City of Vacaville did, shelling out more than $9,000 to reserve a single page. E-mail records and invoices showed the City of Vacaville also paid $3,000 for various digital initiatives, including a promise that Comstock’s would promote the City of Vacaville’s section on social media. A review of the magazine’s social media accounts revealed Comstock’s never did.

On the left, an endorsement letter written by Michael Jasso, the Assistant City Manager in Sacramento. On the right, a similar letter penned by Tim Padden, the Economic Development Manager in Vacaville. Obtained by Solano NewsNet.

Visit Vacaville shelled out the same amount of cash for a similar advertisement. In an e-mail to Solano NewsNet, Reeves said the intention of its advertisement was to “support our Economic Development partners and get a little coverage in the Sacramento region,” adding that the organization’s Board of Directors “approved this purchase.”

Dave McCallum, an account executive with KUIC who also serves as the Chairman of the Board of Directors for Visit Vacaville, affirmed the group’s board approved committing money to the advertisement. The extent of the group’s discussions were unclear.


One month before Padden’s list was sent to prospective advertisers, there were signs that something big was about to impact the local economy.

In late 2019, health officials in China began diagnosing patients with a mysterious new illness, which would later prove to be the result of the novel coronavirus COVID-19.

By the following February, the coronavirus had reached the United States. The first confirmed case of the virus was diagnosed in a Solano County resident who was treated at NorthBay Hospital in Vacaville.

On March 11, the World Health Organization declared the COVID-19 crisis to be a global pandemic. Thousands of people were suddenly dying from the illness, many of whom had pre-existing conditions ranging from asthma to obesity, but some of whom were otherwise healthy. Others became infected with the disease but were otherwise fine. It was difficult to tell how people would react to the virus until they were infected, and by then, it was already too late.

Despite this, the City of Vacaville and Visit Vacaville moved forward with Comstock’s. In an e-mail sent to Solano NewsNet, Reeves said its “commitment to Comstock’s was made prior to the start of the pandemic,” and that “we could not have forseen what was on the horizon.”

But documents obtained by Solano NewsNet through its public records request showed Padden, Busch and others lobbied on behalf of the Comstock’s advertisement supplement weeks after the pandemic began. On April 27, Padden reached out to a City employee requesting she produce a purchase order to be sent to Comstock’s. By then, most businesses had been closed for nearly two months under a stay-at-home order issued by Governor Gavin Newsom.

None of the records furnished by the City showed a contractual agreement that required it or any of its marketing or business partners to remain committed to the Comstock’s initiative. But by April, the tone of the initiative had shifted away from one that highlighted local businesses toward one that elevated Vacaville’s stature as a potential center for the biotechnology industry.

The timing of that was not coincidental: City officials were planning to attend a conference in an attempt to lure biotech companies to Vacaville. As part of its appearance, city officials and key community stakeholders distributed copies of Comstock’s magazine and pointed to its editorial coverage.

No one disclosed to prospective companies that the editorial content was created in partnership with the City of Vacaville and other organizations, and the companies were unaware that the City and Visit Vacaville had helped pay for the supplement, according to people who attended the conference.

They could be forgiven for not knowing: That section, like others before it, didn’t include a clear and conspicuous disclosure that the written content was sponsored, even though federal regulations require it. Comstock’s knew that special section, and others produced before it, were not in compliance: One year earlier, an employee flagged the issue to the magazine’s editors. That employee was me.


In 2019, I was working as a reporter for a local newspaper in Yolo County when I was approached by an editor at Comstock’s about a new digital position they were creating. The magazine had never committed a single person to oversee their website and new digital properties, the editor said, and they realized they needed someone now. Would I be interested?

I knew their editor at the time, Allison Joy, from her previous work before she joined Comstock’s. We got to talking, and I decided to go for it. I was hired in May 2019, and my first task was to help get the magazine’s first special section — the one for the City of Sacramento — online.

A few months later, while reviewing a copy of the magazine, something stood out to me: The Federal Trade Commission required magazines like Comstock’s to clearly and conspicuously disclose paid content with a label that says “advertising,” “sponsored” or something along those lines. Many newspapers and magazines did this, but Comstock’s did not.

That was a big problem: Publications that didn’t comply with FTC guidelines faced fines of more than $40,000 for each offense. At Comstock’s, given the volume of sponsored content in the magazine, an FTC fine could be huge. It could even result in the closure of the company.

Thinking it was an oversight, I reached out to numerous editors, including then-executive editor Tom Couzens, who served in a role similar to that of an editor-in-chief. Couzens was my direct report, and he was ultimately responsible for ensuring the content was labeled appropriately.

“The FTC requires we disclose the advertisement through clear and conspicuous messaging," I wrote, adding information about the potential fine that the magazine faced if the FTC caught wind of what the magazine was doing.

Couzens agreed. He raised the issue with Comstock-Carlson, who said she would consider the issue. Couzens went ahead with a directive that the magazine’s designers label sponsored content in the following issue appropriately, which was set to be printed in October.

His directive didn’t last long. Clayton Blakely, the magazine’s vice president and the top executive in charge of sales initiatives, learned about the change and demanded to know why the sponsored content suddenly had an advertisement label.

“The whole point is that it’s supposed to look like news,” he complained. “No one is going to read or buy it if it’s an advertisement…it makes our job harder.”

Couzens told Blakely to take his complaint to Comstock-Carlson. He did. Couzens argued his case: Not only was Comstock’s non-compliant with federal advertising requirements, the company was choosing to play dirty. Other publication label their advertisement, he argued. Comstock’s should too.

Comstock-Carlson sided with her sales executive and ordered Couzens to rescind his directive.

"Please remove all 'sponsored content' labeling from all pages in the October issue," a defeated Couzens wrote in an email to the magazine's designers one day before the issue was scheduled to be printed.

"My apologies for the extra work," he said.


The sponsored content issue was a turning point in my time with Comstock’s. Things began to spiral from there in a way that would ultimately lead me and others to leave.

For years, turnover had been a problem at the magazine. So, too, had succession planning. Less than one week before my first day on the job, I met with the magazine’s marketing manager, Thomas Hanns, who informed me that he would soon be leaving.

And he did in spectacular fashion: He stopped showing up to work.

His abrupt departure created a slew of problems. As the company’s marketing manager, Hanns knew how every facet of the company’s digital platforms worked. In some cases, he was the only one who knew how they worked. He left without training anyone on the company’s online systems, or providing any insight onto what the company’s digital initiatives were.

His replacement was Guinnevre King, an inexperienced marketing major who was fresh out of college. Immediately after Hanns quit, King was expected to hit the ground running. For several weeks, she struggled to juggle directives issued by Comstock-Carlson, Blakely and others while learning how everything worked.

In July, two months after she joined the company, King flew to Chicago for a week-long vacation. She was burned out, and she needed a break. The move caught everyone by surprise — she told no one at the company about her plans, and no one knew where she was for several days.

When she returned, I offered to take on some of her work, including the online part of the special sections initiative. Couzens immediately bristled at the idea. His tone was clear: Stay in your lane. You’re on our team. That’s sales. We’re editorial.

The truth is, it was never made clear to me which team I was on. The company was essentially divided into three groups: Editorial, sales and design. Editorial was responsible for news content. The sales team sold ads. And the design team put the print magazine together while creating graphics and filming videos for the website.

Among the teams, there was some overlap. A key member of the editorial team was tasked with producing the special sections each month — a sales initiative. The design team was also responsible for producing the advertisements that went into each issue — another sales initiative. King reported to Comstock-Carlson, but her directives often came from Blakely, who was on the sales team.

Couzens also reported to Comstock-Carlson, and she expected to play across teams, just as other editors had done in the past. In his role, she banked on him making sure the editorial content was of high quality, while also playing nicely with the sales team, who would often approach the subject of stories with a request that they advertise in the magazine.

Couzens wasn’t expecting this. He was a career newsman. For more than 30 years, he worked in the newsroom of the Sacramento Bee newspaper, eventually serving as the publication’s sports editor. He was a consummate newsman, honoring the unspoken wall between editorial and sales — the notion that journalism should never be influenced by money.

Those who worked with Couzens spoke highly of his work. But they also said he was, at times, uncomfortable to work with.

“He’s Eric Cartman with an AARP card,” Daniel Hunt, a local news editor for the Sacramento Bee, said in a conversation last year. Hunt said it was not unusual for Couzens to throw a tantrum when he didn’t get his way. Others said he had a knack for exploding at the slightest sign of conflict.

Some of this spilled into the public in 2012 when a local radio personality criticized Couzens for some of his newspaper columns. The criticism infuriated Couzens, and he called the station to make his feelings known.

“This show sucks,” Couzens said in one call, according to a report. “How the fuck is this guy still on the air? Get this guy off the fucking air.”

Couzens didn’t reveal his identity, but the radio station knew it was him: They had his phone number on their caller ID. When approached by a Sacramento News & Review reporter about the issue, Couzens initially said he didn’t know anything about the calls and claimed his phone was hacked. After station officials approached his editors at the Bee with their proof, Couzens came clean, eventually admitting that he lied.

His temper was largely kept in check at Comstock’s until he was overruled on the sponsored content issue. His demeanor toward his subordinates changed drastically, and his relationship with Comstock-Carlson began to sour. But no one bore the brunt of his ire more than me: As the person who initially flagged the advertisement issue, I was blamed for his rift.

Things came to a head in January 2020, when I was forced to take time off to deal with an illness. Couzens responded to my request for time off by making numerous phone calls and sending e-mails demanding an in-person meeting. His message was clear: I’m going to make your life hell.

It didn’t take long before I handed in my resignation (one that Carlson-Comstock refused to accept). Comstock-Carlson did not return a request for comment. Sena Christian, the magazine’s new executive editor — who said months ago she intended to resign, but who still remains employed there — said she had no comment. Blakely did not return an e-mail seeking comment.

As this story was being researched, Comstock’s became aware that I was filings records requests and interviewing their advertisers. In an apparent effort to stop the story, Couzens reached out to the U.S. Attorney’s Office in Sacramento as well as the Federal Bureau of Investigation, who were probing a separate legal issue involving the company.

“Winnie tells me that [he] has contacted at least one of Comstock’s [sic] clients with disparaging comments, attempting to persuade them to no long advertise with the magazine,” Couzens wrote in an e-mail reviewed by Solano NewsNet. “If you need more details, I can get those for you.” (Neither the U.S. Attorney’s Office or the F.B.I. pursued that matter. Couzens resigned a few months later.)


The dysfunction inside Comstock’s became somewhat apparent early last year as city officials in Vacaville and its partner marketing firm, Visit Vacaville, were readying plans to finalize the special section.

In an email dated March 16, Padden emailed Reeves to ask if Comstock-Carlson had provided a “cost break down” in order to gauge how much the City of Vacaville’s special section would run.

“I have reached out to her twice on this with no response,” Reeves responded, to which Padden said he would “send her an e-mail.”

According to a current employee who was familiar with the situation, Comstock’s was dealing with a handful of issues behind the scenes, including a glitch involving their ability to display advertising on their website. That issue stemmed from an apparent lack of knowledge by Comstock’s employees on the basics of their digital advertising platform, which was powered by Google, according to documents passed by the employee and reviewed by Solano NewsNet.

One week after their emails, an editor assigned to oversee the creation of the special section reached out to Padden and Reeves with a list of due dates, but no estimate on the amount it would cost to run the supplement.

In a second e-mail sent April 6, the editor reached out again. Without going into specifics, the editor said it had “been a crazy past few weeks” at Comstock’s.

A frustrated Reeves wrote back, saying that the City of Vacaville and her team “is all waiting to hear back from Winnie — they have questions they want answered before we do anything.”

Two minutes later, Comstock-Carlson wrote back. “Did I miss an email?” she asked.

Reeves reiterated concerns by the City of Vacaville over costs associated with the supplement. Specifically, city officials were worried that they would be on the hook for more money if Comstock’s was unable to secure commitments from other advertisers.

Comstock-Carlson assured Reeves, Padden and others that this was not the case. The city moved forward with its plan and eventually cut Comstock’s a check.

By the time the special section was published, the coronavirus emergency had accelerated. Unable to weather the effects of the pandemic, many local businesses opted to close down — some for good.

The economic effects were felt at Visit Vacaville as well, with Reeves asserting that the organization “needed financial assistance to get through the crisis ourselves.”

But the organization’s push for a large-scale advertisement in a little-read local business publication has rankled some in the community.

“The promotion seemed like a waste of money,” one business owner, who spoke with Solano NewsNet on condition of anonymity, said in a phone call. “Rather than give thousands of dollars to a magazine that no one has ever heard of, why not support local businesses directly? Buy Facebook ads promoting our businesses, or just give us the money — we could use it.”

“We were never in a position to provide monetary assistance to local businesses,” Reeves said. “We did however support them through marketing support and resources for them to get financial help.”

City officials may have been in a better position, though to what extent remains unclear. No one from the City returned a request for comment.

Overall, the advertisement campaign did little to move the needle for the City of Vacaville’s biotechnology hub. But that didn’t stop city officials from trying again: Earlier this year, the City purchased an advertisement supplement on the website of SFGate, a sister publication to the San Francisco Chronicle. Much like the special section that ran at Comstock’s, the SFGate advertisement looked like legitimate news content that was actually produced on behalf of the City. It wasn’t immediately clear how much the City paid for the supplement, but metrics reviewed by Solano NewsNet show it had a much-wider reach than the section produced by Comstock’s.

But it helped things at Comstock’s, at least for a little while. Prior to the global health crisis, things were looking grim for the magazine: Its revenue had fallen to the point where Comstock-Carlson took out a bank loan to keep the lights on, according to a current employee who spoke on condition of anonymity.

Last April, just as the City of Vacaville and its partners were considering a commitment to the magazine’s special section initiative, Comstock’s took advantage of federal pandemic relief assistance, applying for a Paycheck Protection Program (PPP) loan totaling $141,300, according to ProPublica.

As part of its application, Comstock’s reported 13 full-time employees when it applied for the loan, the ProPublica record revealed. A worker with knowledge of the company’s loan later affirmed that count included one full-time employee who had been on medical leave for more than two years, one part-time employee who did not meet the federal reporting standards and one independent contractor who provided payroll support services.

Despite this, the loan was approved. Including interest, the government agreed to forgive more than $142,000 after Comstock’s said 100 percent of the money went to cover payroll costs.

Around the same time, the City of Vacaville and its marketing partners were readying plans for the section. In June, the City cut a check for its portion of the special section that ran in Comstock’s, which totaled over $10,000. All told, the section brought in between $30,000 and $40,000 for the magazine. With the company receiving tens of thousands of dollars from the Paycheck Protection Program, nearly all of the revenue raised from the advertising initiative was pure profit.

That initiative continues to pay dividends for Comstock’s: Following the City of Vacaville’s advertisement, Comstock’s secured commitments from the cities of Woodland and El Dorado Hills for similar initiatives. Material from the City of Vacaville, including Padden’s endorsement letter, helped convince those cities and other groups to come on board.

Meanwhile, the City of Vacaville and some of its stakeholders are still evaluating the return on the investment from their purchase of the Comstock’s ads. Before they can do that, they have to wait for Comstock’s to deliver on what was purchased — or provide some explanation as to why they haven’t so far. If history is proof of anything, it’s that Comstock’s will likely take a while — if they get around to it at all.


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