One of the main responses Mike Rounds has offered to revelations of misconduct in the state's EB-5 visa investment program is that he didn't run EB-5; the Board of Regents did.

Testimony under oath from Northern State University counsel John Meyer on April 24, 2014, in a deposition for the Darley v. SDIBI arbitration contradicts Rounds's statements:

[Darley attorney Jennifer Elkayam]: Or what entity provides SDIBI with the authority to conduct foreign direct investment activities?

[Meyer]: In the State of South Dakota, that area is handled and funded through the Governor's Office of Economic Development, which is a subbranch of the South Dakota Department of Tourism and Development [John Meyer, deposition, Darley v. SDIBI, Los Angeles, California, 2014.04.24, p. 23].

Agreements between GOED and NSU authorizing SDIBI's work show budget items from NSU, but Meyer says those items included little cash:

[Elkayam]: Did SDIBI ever receive funding from NSU at any point in time?

[Meyer]: Well, I notice here it mentions a cooperative effort. That cooperative effort was limited on NSU's part. I have observed, in some of the documentation, that NSU's contribution was roughly $100,000 per annum. The remainder of the budget, which would be much larger, would have come directly from "GOED" or GOED. I should also add that the bulk of that $100,000 contribution would be in provision of office space, the general overhead support, utility support, communication support, et cetera. I believe the actual cash infusion from NSU would be negligible [Meyer, 2014.04.24, p. 25].

Bollen testified in his April 16, 2014, deposition in Darley v. SDIBI that he answered to NSU Dean of Business Clyde Arnold but that such answering was generally limited to cc-ing Dean Arnold on monthly updates e-mailed directly to the Governor's Office of Economic Development. Elkayam asks Meyer about the chain of command:

[Elkayam]: Do you know whether Mr. Bollen reported to Dr. Arnold between 2007 and 2009?

[Meyer]: Actually, he reported to the titular head of the Department of Tourism and State Development or GOED, and I believe that position was sort of a two-hatted division of the secretary of that department [Meyer, 2014.04.24, p. 28].

The titular head of GOED during the specified time frame was Richard Benda.

Meyer says any accountability Bollen had to NSU was on minor accounting matters, not the core operations of the EB-5 program or SDIBI in general:

[Elkayam]: Who did Mr. Bollen report to within NSU between 2007 and 2009?

[Meyer]: Well, we're looking at "Operations" down there at the bottom of this current exhibit, and I would have to say that for operational purposes, for those functions, he reported to whoever was the titular head of the Department of State of Tourism and Development or, as I said, who would also be heading the GOED operations.

[Elkayam]: So no one within NSU?

[Meyer]: Not for operations.

[Elkayam]: For any other purpose?

[Meyer]: What -- what would occur is reconciliation of payroll expenditures. For instance, we just looked at this previous exhibit that's identified as 1(8). Obviously there would be some accounting reconciliations concerning his salary, travel, et cetera [Meyer, 2014.04.24, p. 34].

Meyer says Bollen submitted his primary budgets (the accuracy of which Bollen himself called into question in his deposition) and accounting information to GOED:

[Elkayam]: Did he [Bollen] ever submit any type of budgets for approval to anyone within NSU?

[Meyer] I don't believe he did, to my knowledge. I believe he submitted his budget requests and his accounting of expenditures to GOED [Meyer, 2014.04.24, pp. 34–35].

Meyer states under oath that he does not believe Bollen obtained authorization from anyone at NSU or the Board of Regents for his January 2008 SDIBI–SDRC Inc. contract [p. 45]. He says that the functions described in that contract exceeded the parameters of the SDIBI mission statement approved by the Regents in 1994 [p. 48] as well as the operating authority granted to SDIBI by GOED and the U.S. Customs and Immigration Service [p. 51]. Meyer also says that Bollen and SDIBI received no Regental authorization for memoranda of understanding sent to EB-5 investors [pp. 57–58].

Operating thus outside the bounds of granted authority, as exhibited by SDIBI's off-book partnership with the Hanul law firm, prompted a meeting involving  NSU's new president, Dr. James Smith, in 2009:

[Meyer]: ...there was a meeting that occurred at NSU between myself and Dr. Smith and Rich Benda and Joop Bollen and [V.P. finance and administration] Don Ehrlenbusch, and that meeting would have occurred in July of 2009.

[Elkayam]: And what did you talk about at that meeting?

[Meyer]: The -- you know, it's been five years now and the meeting was attended by myself, because I was asked to come, because there was a concern about the -- the employment of Hanul Law Firm. And there was also a concern at NSU about, shall I just say the activities that had been uncovered, and it was prompted by the transition between Dr. Laurie Nichols, who had been an interim president at Northern, and Dr. Smith's arrival, taking over her duties.

[Elkayam]: You said the employment of Hanul. Was that employment by SDIBI of Hanul?

[Meyer]: There was a concern that there had been no employment that any of us were aware of and that there should not have been [Meyer, 2014.04.24, pp. 56].

This July 2009 meeting fits the narrative that emerges from Bollen's deposition that NSU and the Regents may have been trying to shut SDIBI down and that only intervention from Benda and the Governor's Office of Economic Development kept Bollen and EB-5 going.

Meyer concludes that he does not believe that Bollen "was supervised by NSU in the sense that you would expect as an employee" [p. 73].


Everything comes around....

In an October 10 blog post, Bob Mercer reported that the relationship between South Dakota's EB-5 czar Joop Bollen and Hanul Professional Law Corporation attorney James Park began in a Korean prison:

According to Park’s testimony, Park met Bollen during a failed attempt by Bollen to recruit in South Korea. Park said he helped get a NSU faculty member (who isn’t named) and a friend of the faculty member out of prison for a violation during their recruiting trip to South Korea. That led to Park and the Hanul firm becoming the prime recruiter worldwide for Bollen, except in China [Bob Mercer, "What Could the Rounds Campaign Have Done?" Pure Pierre Politics, 2014.10.10].

Evidently Bollen almost sank South Dakota's EB-5 program on his very first EB-5 recruiting effort in 2004. In his April 29, 2014, testimony in the Darley v. SDIBI arbitration, Park said his law firm's relationship with the South Dakota International Business Institute, which Bollen ran on the NSU campus, began in 2004:

...when SDIBI first came up with EB-5 projects, they were working with a Korean professor in Northern State, and Korean professor told Joop Bollen that "Prime market for this is Korea. So let me set up a seminar in Korea" [James Park, testimony, Darley v. SDIBI JAMS arbitration hearing, Los Angeles, CA, 2014.04.29].

(Yeah, sure, who needs market research when a prof down the hall says, "Hey! Let's go to Korea!"?)

So they set up a seminar and made advertisements in newspaper, which is illegal. So I contacted Mr. Bollen and said, "I'm a U.S. lawyer. I'm an immigration lawyer with a Korean law firm. We are interested in pursuing EB-5 business, and we understand you are having a seminar in Korea. The format you are going by could be problematic. So if you need help, let us help you" [Park, 2014.04.29].

Maybe Bollen should have paid more attention to Park's first contact. Park volunteers this story of what happened when Bollen, prof, and friend touched down in Seoul:

...Joop came to Korea with the professor and his Korean partner from the U.S. for a seminar, and lo and behold, as I warned him, the police came and arrested those two gentlemen for illegal seminar because they charged for the seminar.

So I was at the scene, and we talked to Joop, and our firm got those two gentlemen out of the prison, and that gave us a good relationship with Joop [Park, 2014.04.29].

From that meeting sprang a beautiful relationship, which Park says by 2007 included trips to Cambodia, Taiwan, India, Vietnam, and the Philippines. Their relationship was so cozy that Park and Bollen felt they could conduct transactions worth millions of dollars without writing anything down. (Remember, Park and Bollen are the honyockers who Californian financier David Kang says had Northern Beef Packers' finances in total disarray in mid-2009.) Park says SDIBI and Hanul never had a formal, written contract.

Park thought this wink-and-nod coziness ought to govern relationship for everyone working with state agency SDIBI. He made the following statements to Darley boss Robert Stratmore in an October 4, 2007, e-mail read into the arbitration record:

As I mentioned in my email, Hanul does not have an exclusive agreement signed between Hanul and SDIBI. This is because SDIBI (South Dakota) SDIBI and Hanul felt that substance over form was important. WE wanted to start the work and secure our place by our performance. Furthermore, State government granting any sort of exclusivity is a major endeavor as you may know. Rather than to spend time on formalizing everything, we've decided to use the time on creating results...[Park to Stratmore, 2007.10.04].

If that swishy language (formailize our multi-million-dollar transaction? Pish posh!) doesn't set off your business and legal alarms, well, hey, I have a beef plant in Aberdeen I'd like to sell you.

Hanul is confident that the working relationship with Hanul and SDIBI is sufficient for Darley to take on the marketing efforts that it intends to. Therefore, our agreement would be one of practicality rather than absolute legal right. That is the best that we can offer at this time. We have had no reason to seek cumbersome, and may be impossible, expressed exclusivity from SD attorneys. I hope you can reason our rationale in this regard [Park to Stratmore, 2007.10.04].

Park and Bollen thought the state's lawyers were so darned cumbersome that they didn't even seek the state's authorization to deal with the Darley litigation. During the arbitration hearing, Darley attorney Maxwell M. Blecher asked Park about a hearing involving Darley and SDIBI in December 2008:

[Blecher] Have you ever been appointed as counsel, legal counsel, for any South Dakota entity?

[Park]: No.

...[Blecher]: ...isn't it true that Hanul Professional Law Corporation... acted as the legal representative for SDIBI during that mediation session?

[Park]: Yes.

[Blecher]: ...Was Hanul Professional Law Corporation—to your knowledge, has Hanul Professional Law Corporation ever been appointed as legal counsel for SDIBI?

[Park]: Let me rephrase my answer to be more clear—

[Blecher]: Okay.

[Park]: —if I may. Hanul was never appointed by SDIBI to be SDIBI counsel.

[Blecher]: Okay.

[Park]: Hanul was asked to assist in certain legal activities to prepare for the mediation.

[Blecher]: Okay.

[Park]: If that is representation, then yes; but if that's not, that's what it is.

[Blecher, keenly attentive to slippery passive voice]: Okay. Who asked for Hanul's assistance?

[Park]: It was a discussion between Mr. Bollen and I about the Darley arbitration that was filed at the mediation and how we are going to respond to it. So there was discussion back and forth, and I think I suggested to Mr. Bollen that you can appear as pro per, meaning as your own self, and I offered to assist him with the preparation of materials for that, if necessary.

[Blecher]: But you never—you never did talk to any representative of the Board of Regents in connection with appearing for SDIBI at that mediation, correct?

[Park]: No, we did not [Darley v. SDIBI, JAMS hearing, 2014.04.29].

Park seems to get his dates mixed up: Bollen submitted his illegal pro per pleading in August 2008, well before the December 2008 hearing to which Blecher refers.

Whenever Park advised Bollen, we can clearly see that Bollen and Park winged South Dakota's EB-5 program on a handshake, then graduated to conspiring to conceal a lawsuit and engage in unauthorized legal representation of the state of South Dakota, which South Dakota Codified Law and the State Bar of California, under which Park practices, agree is naughty.

Yet Bollen kept drawing a state paycheck through 2009 and lived fat on a state contract doing the same job for almost four years after that.

The Bollen–Park relationship that drove South Dakota's EB-5 program in its early years began in a Korean jail. Perhaps the South Dakota EB-5 story will end with a similar cozy image of Bollen and Park themselves in jail.


Mike Rounds desperately needs you to believe that his office had little to do with the EB-5 program that has endangered his gubernatorial legacy and his Senatorial aspirations. "...[T]he program and the personnel were responsible to the South Dakota Board of Regents," Rounds avers. "...[A]s governor, I was not involved in the day-to-day activities of the BOR program."

But according to EB-5 czar Joop Bollen, the leads for big EB-5 transactions came from the Rounds Administration:

[Regents attorney Chaka Okadigbo]: Okay. In terms of -- for people that don't know how the EB-5 program works, if -- I assume the regional center was involved in selecting projects for foreign investors to review and decide whether to invest in it, is that correct?

[Bollen] I wouldn't say that. I would say that initially we will receive a lead that would come from the governor's office or the department of agricultural that there is a project that the state has an interest in. I would then forward the contact to the entity that we had a working relationship with, and they then would obtain the information directly from the project typically and they would then do the due diligence of the project and decide if their investors want to get involved in that project or not [Joop Bollen, deposition 1, Darley v. SDIBI, 2014.04.16].

Rounds has tried to portray his "direct interaction" with Bollen as "limited" to updates on efforts by Bollen's South Dakota International Business Institute "by way of staff reports." Yet Bollen's testimony shows two-way interaction, with the Rounds Administration providing the leads like Northern Beef Packers necessary to sustain SDIBI's efforts.


Among the questions Rep. Bernie Hunhoff posed to former Governor Mike Rounds last month about his EB-5 czar Joop Bollen's contract with himself was this loaded query:

Did you know Bollen was asked at deposition "why didn't you sign on behalf of SDRC, Inc." and he responded "it would look silly"? [Rep. Bernie Hunhoff, question 1d, letter from Government Operations and Audit Committee to Michael Rounds, 2014.09.16]

The deposition of Joop Bollen in Darley v. SDIBI shows that Rep. Hunhoff got it wrong. Bollen did not say it would look "silly." He told Darley attorney Jennifer Elkayam that it would have looked "goofy":

[Elkayam]: Why did Mr. Park sign as SDRC -- director of SDRC Inc.?

[Bollen]: First of all, this document was merely to advise the USCIS that a new entity was involved in the operational aspects of the regional center, and we are supposed to advise the USCIS if there is such a change. That was the whole function of this MOU and the reason why I -- Mr. Park signed it is because I had a conversation with him and said, "It looks so goofy for me to sign twice with the same signature," so he said, "Well, I can sign for it as well," so I said, "Okay, that's fine" [Joop Bollen, deposition 2, Darley v. SDIBI, 2014.04.17, p. 221].

Goofy indeed. But somehow I don't think that's the word the USCIS would use to describe signing a document and submitting false information concerning the administration of a federal program.


The hook in Denise Ross's blockbuster EB-5 story today is that Governor Mike Rounds attended attended a meeting in the Capitol with economic development chief Richard Benda, EB-5 czar Joop Bollen, Northern Beef Packers CEO David Palmer, Hanul Law Firm and Bollen pal James Park, and Maverick Spade financier David Kang where his South Dakota Certified Beef Program, a key to the Northern Beef Packers plan, was discussed. Kang says Governor Rounds was there simply to meet and greet, not blatantly inconsistent with his statement of ignorance of EB-5's "transactional details." Nonetheless, the Rounds campaign is claiming no recollection of this meeting.

The hammer in Denise Ross's report is financier Kang's damning assessment of Bollen's business savvy and ethics. Kang says that Bollen and Park controlled Northern Beef Packers, shut Palmer and experts out, and ran the packing plant into the ground:

Kang describes finding Northern Beef Packers in financial disarray in 2009, with Joop Bollen and Hanul's James Park running operations and having control of the plant's accounts and money.

"They were in complete control of any and all finances," Kang said of Bollen and Park. "Financially it was an utter disaster. They didn't have any of the financial records organized. They didn't work with any of the lienholders" [Denise Ross, "Source: Bollen, Lawyer in Control of Northern Beef Operations, Finances," Mitchell Daily Republic, 2014.10.17].

Kang's statement confirms what we've seen in subsequent contracts with NBP in which Bollen asserted control over the project and forced them to spend money to suit his wishes.

And while Bollen likes to puff out his chest over his urgent entrepreneurial wizardry, Kang says Bollen and Park didn't know what they were doing:

He describes Bollen and Park as, at best, inept.

"They were in over their heads. They didn't understand how to do development, construction projects, things of that nature. That's ultimately why they fell flat on their face," he said [Ross, 2014.10.17].

Kang also calls them chiselers. The $2.5-million "success fee" originally apportioned to Maverick Spade for securing the $30-million Epoch Star loan may sound like robbery, but Kang says his firm did real work to clean up the financial mess in which Bollen and Park had drowned Northern Beef Packers. In return, Bollen and Park gave Maverick Spade the brush-off:

"They had us flying here, there, South Dakota, Korea, Asia, everywhere trying to get financing. We were working in three time zones," Kang said.

Kang said once it became clear that Chinese Development Industrial Bank out of Taiwan was willing to loan Northern Beef $30 million through its subsidiary, Anvil Asia Partners, Hanul and Bollen began working directly with bank officials.

"They pretty much got what they wanted and from there said, 'Bye-bye,' " Kang said, adding that his firm had not been paid much beyond an initial retainer fee. "That is one of the many reasons why Maverick exited the project" [Ross, 2014.10.17].

A July 23, 2010, amendment to the NBP–Epoch Star loan agreement changed Maverick Spade's "success fee" to $750,000. Kang tells Ross his company ultimately received $950,000.

But even screwing vendors like Maverick Spade who brought millions into the packing plant, Bollen and Park weren't able to turn Northern Beef Packers into a sustainable business.

So maybe we have our answer to how Mike Rounds's biggest legacy project made $167 million go poof. The guys running it were bumblers... much like the Rounds campaign staff that hasn't found a working defense to the hailstorm of EB-5 news.


Among the absurdities revealed by Joop Bollen's April 16–18 deposition is the EB-5 czar's haughty disdain for following the basic rules of contracting with private vendors.

First, some background (I know, it's maddening, but the EB-5 scandal is complicated!):

Darley International sued to force the South Dakota International Business Institute into arbitration over a contract dispute. Darley signed a contract with the Hanul Law Firm in October 2007 to recruit EB-5 investors in China for South Dakota projects. Darley alleged that Hanul failed to deliver recruitment documents that the contract demanded at a December 2007 EB-5 recruitment trip to China. Bollen incorporated SDRC Inc. in January 2008 to take over the lucrative recruitment duties specified in the Darley-Hanul contract. Darley went after Bollen's SDIBI because Darley perceived Hanul to be SDIBI's partner in managing the EB-5 program and because SDIBI chief Bollen had been in contact with Darley boss Robert Stratmore and appeared to be aware of and participating in the negotiation of the Darley–Hanul contract.

Now the fresh meat and potatoes:

One fact that saved SDIBI from facing a breach-of-contract ruling is that SDIBI had no written contract with Darley or Hanul. Even though Bollen had been pals with Hanul boss James Park since a fortuitous meeting in Korea in 2004, Bollen never firmed up the SDIBI–Hanul relationship in writing. In the April 16, 2014, deposition, Board of Regents attorney Chaka Okadigbo tries to suss out why not:

[Okadigbo]: Okay. Did James Park at any point ever ask you for a formal written agreement between SDIBI and Hanul?

[Bollen]: Very early on, but I explained to him the constraints that I was operating under and he understood those [Joop Bollen, deposition 1, Darley v SDIBI, April 16, 2014, p. 17].

Constraints? What constraints?

Bollen explains that, when South Dakota's EB-5 regional center was one of the few in the nation, he received numerous contacts from recruiters angling for a profitable contract. He forwarded those contacts on to Hanul for James Park to handle (and yes, you should start wondering whether Bollen did any work at all in his state job).

The reason why I connect them to Hanul is because of the constraints I'm on, under, I cannot sign agreements with outside entitites. Hanul is a seasoned law firm that knew my constraints and knew how to work with my constraints and still produce for the State of South Dakota [Bollen, 2014.04.16, p. 22].

Bollen repeats similar lines about "constraints" on pages 23, 27, 28, and 35. These assertions make no sense. A state agency like SDIBI can make written agreements with private contractors. That's how the Board of Regents, who technically employed Bollen and housed SDIBI, builds stadiums. That's how the Department of Tourism, which in the Rounds Administration was also technically Bollen's boss, gets super-slick promotional materials worth millions of dollars from advertising firm Lawrence & Schiller. If vendors want to provide services to the state, the state hands them the state vendor manual, puts out bids, and writes a contract to the vendor who offers taxpayers the maximum value.

But on page 60–61, Bollen finally makes clear his perception of the "constraints" that prevent him from operating like every other state employee:

[Okadigbo]: While you were SDIBI director, what was your understanding of what you needed to do if you wanted to get a written agreement in place?

[Bollen]: I wouldn't even go there because it doesn't work in the system, so that is not something I would even attempt to do.

[Okadigbo]: Okay. And just so that we understand, why wouldn't you attempt it?

[Bollen]: Because it's a bureaucratic -- my job was doing very entrepreneurial things in a very bureaucratic environment, and a typical bureaucrat is not going to sign off on the kind of activities that I was instructed to do, so it would become bogged down in the system by people who would rather not make any decision at all.

[Okadigbo]: Okay.

[Bollen]: And therefore there would be too many time delays before it would be practical, become practical [Bollen, 2014.04.16, pp. 60–61].

In case Joop's accent throws you off, here's the translation: The things I've been instructed to do can't wait for the dopes at Northern and in Pierre. I'm far too important to follow their rules.

(Remember, the oh-so-hurried and self-important Bollen is the same guy who told Chinese investors there was nothing wrong with investing in a beef plant that was taking years longer to build than originally planned.)

Rather than submit to the laws and rules that every responsible state employee accepts as necessary safeguards of public dollars and public trust, Bollen looked for partners like Hanul who would help him dodge state oversight by doing business on a wink and a nod. When the state became aware of the Darley litigation that Bollen tried to conceal from them, the state could see Bollen's arrogance and corruption. Yet rather than acting on its obligation to hold every state employee accountable to the public, the Rounds Administration rewarded Bollen with a no-bid contract and even greater opportunity for unsupervised profiteering.

South Dakotans, Joop Bollen told us and our rules to jump in the lake. And Mike Rounds said, "Heck of a job, Joop! Keep up the good work!"


One of the numerous violations of state law Joop Bollen appears to have committed while running Mike Rounds's EB-5 visa investment program is his representation of the state in court in the Darley v. SDIBI lawsuit. Bollen submitted a pro per pleading to federal court in California to defend the agency he ran, the South Dakota International Business Institute, from EB-5 recruiter Darley's effort to force SDIBI into arbitration over a contract dispute. Bollen is not a lawyer. He never had Attorney General Larry Long's authorization to speak for the state in court. He broke the law to conceal the lawsuit from his bosses, a violation of state risk management policy.

But when deposed by Board of Regents attorney Chaka Okadigbo on April 16, 2014, Bollen denied that he authored that August 22, 2008, pleading:

[Okadigbo]: Okay. I've just handed you a document, it appears to be a pleading that's filed according to it, in Pro Per, it has your name and SDIBI's information on the top left part of the pleadings. So my question to you is, you had told Mr. Meyer about this case in January of 2009, but according to these pleadings, if we go by the proof of service that is located I believe on the last page -- well, second to the last page before the page that says mailing list, it indicates a proof of service date of August 22, 2008. So I guess my question to you is, looking at these pleadings, it's my impression that you, on behalf of SDIBI, had this document filed in federal court, is that correct?

[Bollen]: It's not correct.

[Okadigbo]: Okay. Can you tell me -- first of all, did you participate in the preparation of the pleadings that I've just handed to you?

[Bollen]: The only thing I did was prepare the statement of fact that I e-mailed to Hanul, from what I recall.

[Okadigbo]: Okay. So you prepared the statement of fact?

[Bollen]: Statements of fact.

[Okadigbo]: Statements of fact.

[Bollen]: In e-mail format, yeah, just Word document with the bullet points.

[Okadigbo]: Okay. So who came up with the legal arguments in this pleading?

[Bollen]: I would suspect Hanul.

[Okadigbo]: Okay. It wasn't you?

[Bollen]: It wouldn't be anybody -- it was not me, that's correct [Joop Bollen, deposition 1, Darley v SDIBI, April 16, 2014, pp. 93–94].

Review the pleading. It has Bollen's signature. Whoever, if anybody, cribbed it for him, Bollen took ownership of it. And by preparing, signing, and submitting it, Bollen broke state law in a clear attempt to hide his shady activities from his superiors.


Yup, it's Joop all day!

The Aberdeen American News does us a public service and posts the deposition of Mike Rounds's EB-5 czar Joop Bollen in the Darley v SDIBI. The deposition spans three days, April 16, April 17, and April 18, 2014.

Where shall we start? Let's look first at Bollen's testimony that he saw himself as a czar, writing his own ticket without any oversight.

On April 17, 2014 (p. 140), Darley attorney Jennifer Elkayam asks Bollen to review an agreement between the Department of Tourism and State Development that indirectly employed him and the South Dakota International Business Institute that Bollen ran on their behalf from the Northern State University campus. That agreement, one of several defining the functions DTSD authorized Bollen to perform, ran from January 1, 2007, to June 30, 2007. Elkayam asks specifically about a budget section on foreign direct investment activities, which would include Bollen's EB-5 visa investment activities:

Clip from DTSD-SDIBI agreement, Jan–Jun 2007

(my annotations in green indicate budget sources)

Elkayam asks Bollen to explain what "Mr. Bollen will devote 80% of his time on this project" means. Mr. Bollen says it means nothing:

This was -- I don't think anybody ever reviewed any of these documents. They were prepared by me, but I never ever received any feedback on whether it's okay. It just was pretty much an automatic approval that we would get for these projects. So I do not recall exactly how my time was devoted, but you can connect it somewhat to the travel below [Joop Bollen, deposition 2, Darley v. SDIBI, 2014.04.17, pp. 140–141].

Elkayam asks if the agreement meant Bollen spent 80% of the time the state was paying him for operating and managing the EB-5 regional center. Bollen says no:

You know, this number is just a very rough estimate. Most of the export promotion projects I already had situated such that my time wasn't as much needed anymore. So these projects were all ongoing on the export promotion side, so even though I might have been temporarily putting a little bit more time on the foreign direct investment, the export promotion projects were still going full force, but my involvement was not as much anymore because my assistants were able to handle and I would just do major supervision of the other projects [Bollen, 2014.04.17, p. 141].

The Rounds Administration was paying Bollen $32,800 to spend the first six months of 2007 working on EB-5 investment and other fishing trips for foreign capital. Bollen did not spend 80% of his time on such work. He passed the work to assistants while he focused on "major supervision," which sounds like a euphemism for feet on the desk.

Fake budgets with meaningless numbers, automatically approved—I guess that's what we can expect from Mike Rounds.

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