EB-5 czar Joop Bollen's response to the Government Operations and Audit Committee's inquiry into his activities on behalf of the State of South Dakota is rich with innuendo, insult, and absurdity. The greatest absurdity packed into his literary fabrication is the suggestion that he intended his private corporation to be a revenue stream for the state and that the state willingly let that revenue stream go.

Recall that Rep. Kathy Tyler (D-4/Big Stone City) charged in September that when Bollen used his state authority to sign a contract with his own newly formed private company, SDRC Inc., in January 2008, he laid the ground work to divert EB-5 administrative fees into his own pocket. Rep. Tyler said that scheme ultimately defrauded the state of $140 million. Other estimates have placed the fraud figure at $120 million.

Amidst all the defenses of EB-5 offered by Mike Rounds and the South Dakota Republican Party during this year's Senate campaign, none of Bollen's protectors ever pushed back on that charge. Now Bollen himself, in a well-thought-out and long-delayed explanation, confirms the mechanism that Rep. Tyler outlines: the state, through its SDIBI office at Northern State University, could have kept control of SDRC Inc. and put more money in state coffers; privatization sent that money into Bollen's hands. Says Bollen in his November 10, 2014, letter to GOAC:

Also like NPII [Northern Plains International Incorporated], SDRC Inc. would create a fund of monies for NSU to use [p. 5].

...my initial intention for SDRC, Inc. was to create and income stream for SDIBI... [p. 8].

...taking SDRC, Inc. private was never my intention but rather it was supposed to create an income stream from FDI [foreign direct investment] activities for SDIBI just like NPII did in regard to export promotion [p. 9].

Bollen confirms Tyler's statement that recruiting and managing EB-5 visa investment activities could have provided the state with direct revenue—not just increased sales and property tax revenue down the road from businesses boosted by EB-5 money, but up-front fees from investors paid directly to Pierre.

That claim (and if Kathy Tyler and Joop Bollen both make the claim, are we ready to call it fact?) leads us to the 140-Million-Dollar Question:

What would motivate the State of South Dakota to give up a multi-million-dollar revenue stream?

Bollen says legal liability motivated that self-denial. Run SDRC Inc. honestly, write clear contracts with everyone you deal with (unlike Bollen, who's off-book operations brought us the Darley litigation), and there's no more liability to running EB-5 than there is to running public universities with dangerous chemistry labs and dormitories with slippery shower floors. The Darley litigation cost the state $510,000 over five years; keep SDRC Inc.'s functions under state control, and EB-5 pays its own lawyer bills and leaves millions for ongoing teacher pay raises (oh! Ha ha ha! Hee hee hee!) or road work or rebates for South Dakota taxpayers.

Politics could motivate South Dakota to turn down real money. Governor Dennis Daugaard rejects $250 million a year from Medicaid expansion because he doesn't want to help President Obama and those darn poor people who need to stitch some bootstraps to their bare ankles. But in 2009, EB-5 has no political component. Governor Rounds believes his EB-5 idea and his man Bollen are great for South Dakota. EB-5 boosts the budget without taking a dime from any South Dakota taxpayer.

We're running out of rational options.

Board of Regents executive Jack Warner told GOAC yesterday that they didn't fire Bollen because they needed Bollen's testimony to fight the Darley lawsuit. Perhaps privatizing EB-5 to SDRC Inc. was just a big carrot to keep Bollen cooperating. But why couldn't we use the stick? Pull Bollen out of his NSU office on February 1, 2009, hand Bollen his pink slip and a subpoena, declare SDRC Inc.'s agreement with the state null and void based on Bollen's lack of authority to sign that contract, and run EB-5 as the state revenue stream Bollen said it was supposed to be. By 2009, the state should see Bollen (and I think new NSU President James Smith saw Bollen) as an arrogant ass who is throwing around state weight that's not his to throw. If I'm in charge of South Dakota, I shut Bollen down. We don't need Bollen!

Or do we?

Or, more to the point, does somebody need Bollen to bring in the EB-5 money privately and use it for something more appealing than propping up the state general fund?

Let's just say it: privatizing EB-5 and denying the State of South Dakota millions of dollars is a bad idea. The most rational reason I can think of to let Joop Bollen deny the state millions of dollars is that I might get a cut of that money.

I invite alternative explanations. But when I add Joop Bollen's statements to all the stories we've been told about EB-5, I come to the conclusion that the most logical explanation on the table is that someone was on the take.


Among the highlights from the Government Operations and Audit Committee hearing happening right now on the EB-5 scandal, Board of Regents exec Jack Warner provides the first direct answer we've heard as to why the state didn't fire EB-5 czar Joop Bollen for his multiple violations of Regental policy and state law in 2008 and 2009. "If we were going to mount a successful defense" in the Darley litigation, "we needed to rely on Mr. Bollen's testimony."

Recall that in August, the Regents, the Attorney General, and the Governor's Office told us that Bollen got no immunity deal, even though he had pressed for one. But today, Warner is implying that in 2009, Bollen got something like immunity from firing in return for his help in beating back the Darley lawsuit. Does the need to beat Darley also explain why the state granted Bollen his private contract to run EB-5 for personal profit after 2009?

Attorney General Marty Jackley says he never granted Bollen immunity from prosecution, but Bob Mercer reported yesterday that Jackley apparently granted Bollen immunity from interrogation. AG Jackley told Mercer, "I did not meet with Mr. Bollen personally either during or after the investigation, nor have I talked with him." Mercer reported AG Jackley's statement that he had spoken with federal investigators and reviewed the information they received from Bollen. Incredibly, though, AG Jackley has never seen fit to conduct his own inquiry into Bollen's state-level misdeeds.

Strangely, AG Jackley felt the need to repeat himself today in a press release. Let me quote in full, so there is no misunderstanding:


Pierre S.D. - Attorney General Marty Jackley confirms that on more than one occasion Joop Bollen voluntarily agreed to be interviewed by law enforcement authorities acting in joint cooperation. This has been set forth in both Joop Bollen's recently filed responses to GOAC questions and the testimony of the Attorney General to GOAC on July 29, 2014. Both the Division of Criminal Investigation and the Attorney General's Office have received Joop Bollen's interview information from federal authorities, along with voluminous other witness information as part of cooperative law enforcement efforts some of which were completed by DCI, FBI or both agencies jointly. Based upon all of the investigation information, the Attorney General authorized moving forward with state criminal charges as more fully set forth in the criminal complaint and arrest warrant drafts of October 8, 2013, as provided to GOAC [South Dakota Attorney General's Office, press release, 2014.11.13].

In one of its rare allusions to EB-5 (an affair that has received minimal attention, investigation, or analysis from Pat Powers), the GOP spin machine claims that this press release "refutes" Mercer's claim that AG Jackley didn't interview Bollen. The GOP spin machine then dismisses the Mercer article as "shenanigans."

This assertion from Powers is problematic on many fronts.

  1. Bob Mercer makes no claim. He quotes Attorney General Marty Jackley directly. AG Jackley says (let's repeat it, to be clear), "I did not meet with Mr. Bollen personally either during or after the investigation, nor have I talked with him."
  2. The AG's press release does not refute anything Mercer reported. The press release says the AG received information from federal authorities. The press release does not say the AG spoke or met with Bollen. The press release does not say Mercer misquoted Jackley. The press release has no refutatory power against anything Mercer said (or for that matter, anything I said in my follow-up blog post on the topic).
  3. AG Jackley and the GOP gain no apparent advantage from making this claim. Saying Bob Mercer got his facts wrong just for fun is a bad idea, especially when one has no information to call into questions the facts he reported. The AG's press release only emphasizes the fact that he didn't do his own work on the EB-5 investigation. Yes, the DCI has apparently worked in conjunction with the FBI. But AG Jackley's convoluted verbiage here suggests that he has ignored an opportunity to do basic law enforcement and turn the heat up himself on a main player in a potential scam.

Attorney General Marty Jackley has acted shockingly incurious about Joop Bollen's clear violations of law, policy, and public trust. BOR's Jack Warner suggests that Bollen brilliantly boxed state officials into a deliberate incuriosity that let Bollen continue what smells more and more like a scam for personal profit.


In March 2013, South Dakota officials received eight subpoenas from federal officials seeking information about the state's use of the EB-5 visa investment program. Two men central to that EB-5 program were former Governor's Office of Economic Development secretary and EB-5 loan monitor Richard Benda and EB-5 czar Joop Bollen.

Attorney General Marty Jackley told us in November 2013 that his office never interviewed Richard Benda. Now AG Jackley tells us he didn't question Bollen, either:

“I did not meet with Mr. Bollen personally either during or after the investigation, nor have I talked with him,” Jackley said in an email.

“However, as he indicated in his responses because EB-5 is a federal program he met with federal authorities on several occasions, and I and DCI (state Division of Criminal Investigation) have reviewed those related reports during the state investigation,” he continued.

Jackley added, “I'm planning on further reviewing the materials recognizing what I've said from the beginning that EB-5 is a federal immigration program that federal officials have or are looking at for potential federal criminal violations” [Bob Mercer, "AG: Bollen Wasn't Questioned in Benda Investigation," Aberdeen American News, 2014.11.12].

Something goes wrong enough with a state economic development program being run by a couple former state employees that the FBI comes asking questions, and the Attorney General doesn't think it behooves him to talk with the leaders of that program? AG Jackley finds enough evidence against Benda to call a grand jury and prepare an arrest warrant against Benda for grand theft, but he never thinks he ought to talk to Bollen, the man running the company that had to process the money Benda allegedly stole?

Just as the federal aspect of EB-5 didn't stop Jackley from preparing to arrest and indict Benda, it should not stop him from questioning, not to mention arresting and indicting, Joop Bollen. Private investigation has uncovered multiple state laws and policies that Joop Bollen violated. Every one of Bollen's state-level violations—conflict of interest, fraudulent expropriation of state authority and revenue, etc.—stands independently of any detail of federal immigration policy and is entirely the South Dakota Attorney General's responsibility to prosecute.

So, Attorney General Jackley, do you think it might be time to play catch up and talk to Joop Bollen?


Joop Bollen is trying to distract the Government Operations and Audit Committee from his illegitimate contract with himself, his apparent mismanagement of Northern Beef Packers, and his multiple violations of state policy and law by claiming that reporters like Denise Ross and Bob Mercer have wrecked South Dakota's chances of making more money from the EB-5 visa investment program.

Joop Bollen appears to forget that Governor Dennis Daugaard yanked Bollen's contract and put EB-5 on ice before any journalists started digging into South Dakota's EB-5 program. Bollen's own narrative to GOAC suggests that many in the state wanted to back away from the "liabilities" of EB-5 (which were what, Joop, if everything was being run properly?) back in 2009; the program hung on only because Bollen, Richard Benda, and the Governor's Office wanted to keep that money train rolling. Bollen ignores the fact that South Dakota at his behest (and with Mike Rounds's support) gave up the key competitive advantage of public, state-run status for its EB-5 program, making it harder for us to stand out among the growing number of EB-5 Regional Centers.

Maybe Bollen should switch to blaming Obama. Monday, the President announced that the U.S. will offer new, longer visitor visas to Chinese citizens. Starting today (November 12), tourist and business visas for Chinese visitors jump from one year to ten years. Student and exchange visas stretch from one year to five years.

Keep in mind that one attraction of EB-5 visas has been for wealthy Chinese to buy their kids' way into the country so they can attend American universities. But EB-5 visas cost $500K in at-risk investment plus tens of thousands in fees for lawyers and middlemen like Joop Bollen. President Obama's visitor visas don't give permanent residency the way an EB-5 visa can, but five years on an extended visa for a $160 application fee might sound like a bargain to a lot of folks considering EB-5.

South Dakota reporters are not killing EB-5. South Dakota has lost its EB-5 edge due to decisions made by South Dakota's EB-5 czar and his collaborators in state government. The President's new visa deal with China may reduce EB-5 demand even further.


During his Senate campaign, candidate Mike Rounds insisted repeatedly that, as governor, he had no involvement with the "transactional details" of South Dakota's visa investment program. When asked by the Government Operations and Audit Committee who worked out the details of the plan to allow the state employee running EB-5 to privatize the program into his own private corporation, Rounds wrote on September 22, 2014, "I did not participate in those specific transactional details."

That former state employee, Joop Bollen, offers his account of the creation of that privatization plan to GOAC. After a series of interactions with a variety of state officials, Bollen comes to August 24, 2009:

Tim Engel emails my attorney indicating he's sending a draft agreement between TSD and SDRC, Inc., that Richard Benda had reviewed it and approved the terms. The email indicates that the draft had been reviewed and approved by Richard Benda but would be subject to final review and approval by Neil before Richard would sign it [Joop Bollen, letter to Government Operations and Audit Committee, 2014.11.10, p. 8].

Tim Engel was and is the attorney for the Governor's Office of Economic Development, which in 2009 was part of the Department of Tourism and State Development (TSD). SDRC Inc. is the private corporation Bollen created. Richard Benda was the GOED Secretary.

And Neil—who's Neil?

It would seem that in August 2009, the only Neil in a position in state government to be anywhere in the chain of command above a cabinet secretary like Benda would have been Neil Fulton, chief of staff to Governor Mike Rounds from September 2007 to June 2010.

Bollen says Fulton had to review and approve the TSD–SDRC Inc. contract. Last spring, Fulton denied having any direct involvement with that contract:

The tie between Bollen’s SDRC and state government deepened in 2009 when the contract was drawn. Sveen represented SDRC, while Benda’s department had its work performed by Tim Engel, a lawyer at the May Adam Gerdes and Thompson law firm in Pierre.

Fulton worked for the MAGT firm before accepting his appointment as Rounds’ chief of staff. Fulton said he was aware of the contract and thought he spoke with Engel once about it but wasn’t involved beyond that [Bob Mercer, "As EB-5 Use Quietly Expanded, ‘It Was Not a Plot,’ Official Says," Black Hills Pioneer, 2014.05.03].

Here are your logical possibilities:

  1. Bollen made a false statement.
  2. Fulton forgot.
  3. Fulton fibbed: he approved the contract (though tell me, please: do chiefs of staff have authority to approve any formal government contracts or other actions?).
  4. Fulton parsed: he wasn't involved in the contract, but when Richard Benda passed it up the ladder for approval, Fulton handed the contract to the man who had the authority to review and approve it—Fulton's boss, Governor Mike Rounds.

Let's review why this all matters: Joop Bollen ran South Dakota's EB-5 program for Mike Rounds and Dennis Daugaard. From 2004 to December 21, 2009, he ran it as a state employee. On December 21, 2009, Bollen quit his state job. On December 22, 2009, Bollen signed a five-year contract on behalf of SDRC Inc. with GOED to do pretty much the same EB-5 recruitment and management he was doing while working for the state. Bollen, Benda, and maybe unknown other SDRC Inc. employees and partners made pretty good money on this private gravy train.

One hinky part of this deal is that Bollen used his position as a state employee to sign a contract locking his private SDRC Inc. in as the state's partner in EB-5 in January 2008. The state allowed Bollen to do this and rewarded him with the December 2009 no-bid contract even though numerous state officials knew that Bollen had broken a tub of state laws.

Mike Rounds has told us he had nothing to do with this stunningly bad management.

Yet Joop Bollen is telling us that Mike Rounds's chief of staff had to approve Bollen's golden parachute in 2009.

And if Chief of Staff Fulton did his job and handed that contract to his boss for approval, then Mike Rounds transacted one of the central details of the EB-5 program... in direct contradiction to the words he said to get elected Senator.

Update 20:21 CST: Recall how Rounds explained the GOED–SDRC INc. contract to Bob Mercer at the beginning of October:

[Rounds]: Not unlike the hundreds or thousands of state agency contracts, this transaction was handled at the department level and they utilized department counsel. I was aware of the desire to privatize the program in order to better compete with the 500 regional centers located around the country. I was advised that there were only two state government-managed regional centers and that privatization would help South Dakota compete at the national level. From a competitive standpoint, I agreed with the concept of privatization. I was not involved in the transactional details nor did I review the contract [emphasis mine; Bob Mercer, "Rounds Answers Reporter's Questions on EB-5 Scandal," Black Hills Pioneer, 2014.10.02].


Mike Rounds has gotten by with a big lie; now his EB-5 czar, Joop Bollen, tries to do the same thing.

Here is the audacious central narrative of Joop Bollen's response (don't forget page 20!) to the Government Operations and Audit Committee's inquiry into his activities as director of South Dakota's EB-5 visa investment program (I paraphrase):

EB-5 was everyone else's idea. The state authorized everything I did. Privatizing EB-5 was the only option left to save the program. The state could have made millions from EB-5, but the state didn't have the guts to see it through. I not only did nothing wrong but did wonders for South Dakota. State officials and media have destroyed that program and lied about me. F--- you.

There is no contrition in Bollen's response, no acknowledgement of any wrongdoing. Instead, he appears ready to fight for total vindication.

Consider the charge that Bollen defrauded the Board of Regents and the state of South Dakota by contracting EB-5 out to his own private company. Bollen says...

  1. He signed no contract with himself; the January 2008 agreement between the SDIBI that he ran for the state and the SDRC Inc. that he incorporated was merely an explanation to the USCIS of a new element of South Dakota's EB-5 program.
  2. The Governor's Office of Economic Development told him to create SDRC Inc.
  3. He didn't consider himself the owner of SDRC Inc. until June 2009.
  4. He intended SDRC Inc. to be a revenue stream for the state, but in 2009, "it appeared that NSU and the state system didn't have the stomach to accept the liabilities that were associated with the entrepreneurial activities they asked for and encouraged me to establish and for which I was hired" [Bollen, 2014.11.10, p. 9].

In other words, a contract is not a contract (lawyers, start your engines), and the state was too chicken to take the revenue stream SDRC Inc. offered.

Consider the charge that Bollen hauled away state documents without permission when he quit his job at Northern State University and walked away to the golden parachute of doing the same job at his private company. Bollen says...

  1. GOED actually owned those documents, not NSU.
  2. GOED told him to take those documents.
  3. NSU President James Smith defamed him by saying otherwise.

Do you hear the lawsuit threat? Bollen sounds ready to go to war with anyone who got in the way of his operation, whether it's the reporters who've been uncovering the most damning information about his self-dealing corruption or the president of NSU who came to power in 2009 and found Bollen's activities incompatible with Northern's mission.

Bollen drops as many other names into his narrative as he can, so that just in case anyone does decide something went wrong with EB-5, he can blame everyone else. According to Bollen...

  1. Bill Janklow gave Bollen and SDIBI its real authority back in 1995 because Bollen was doing such good work [p. 2].
  2. NSU President Hilpert got SDIBI more closely involved with GOED in 2000 [p. 3].
  3. Richard Benda persuaded SDIBI to pour EB-5 money into Northern Beef Packers in 2006 [p. 3].
  4. GOED mandated that SDIBI work with the Hanul Law Firm (i.e., it wasn't just some hinky, off-book deal between Bollen and his Korean jail-break buddy James Park) [pp. 3–4].
  5. Maurice "Morrie" Berez "strongly suggested" SDIBI replace the EB-5 equity model with the new loan model under which Bollen created his private company and numerous separate private loan funds.
  6. In its January 2008 agreement with SDIBI, GOED essentially directed Bollen to create SDRC Inc. [p. 5]
  7. Regents lawyer Jim Shekleton and Regents exec Tad Perry had Sherry Anderson audit SDIBI's finances in February and March 2009.
  8. NSU lawyer John Meyer was keenly interested in the successful investment of the EB-5 money flowing to the Huron turkey plant in April 2009 and was advising Bollen on how to manage those investment flows [pp. 6–7]. (Note that this assertion sounds absurd: throughout his statements in the Darley litigation, Meyer portrays NSU as not exercising any role in SDIBI's operations. Bollen's burning of the Regents with his self-representation of SDIBI in the Darley lawsuit would likely have inclined Meyer to keep NSU away from any further risk of liability. NSU's focus during this time appeared to have been to put SDIBI on hold, not facilitate its activities.)
  9. Richard Benda, GOED lawyer Tim Engel, NSU VP Don Erlenbusch, John Meyer, and Dr. James Smith all knew Bollen was going to privatize SDRC Inc. and all approved of the idea.
  10. Assistant Attorney General James Hallem was included in the privatization conversations [p. 8].

Joop's message: Don't try hanging me. If EB-5 is a hanging crime—and it's not, it's fabulous!—you're hanging all the decision-makers above me.

Bollen's response is a belligerent, legalistic tour de force. He pins success to himself and culpability to everyone else. And he makes clear he's playing not just to escape but to win. Let's see if our GOAC legislators have the stomach to sift fact from arrogant fiction in Bollen's tale and get the straight story on EB-5.


Joop Bollen has finally complied with the Government Operations and Audit Committee's request for information about the EB-5 visa investment program that he ran for the state. GOAC has posted his November 10 e-mail response (plus the page 20 that got skipped in the first PDF). I'm still studying his answers, but the preface to his response, dripping with Bollenesque arrogance and snark, guarantees he will not receive a Christmas card from the best reporters in the state.

Bollen makes the following statements in his preface:

  1. He can't speak freely, because the FBI is still investigating EB-5.
  2. The FBI was targeting deceased Governor's Office of Economic Development chief Richard Benda.
  3. Bollen cooperated fully with two FBI interview requests in 2013.
  4. EB-5 was a "fabulous economic development tool" (shades of Oliver North!), bringing over $350 million in investment and over 7,000 jobs to South Dakota.
    1. This is the third major estimate we've heard of the capital/jobs-creation record of South Dakota's EB-5 program.
    2. In late October, Rory King, attorney for bankrupt EB-5 project Northern Beef Packers, contended in letters to the editor that EB-5 drew $400 million and created "directly or indirectly" over 8,000 jobs.
    3. In the press and the SDPB debate, Senate candidate Mike Rounds, the governor who got EB-5 rolling in South Dakota, claimed that EB-5 brought over $600 million and over 5,000 jobs to South Dakota.
    4. In September, I found that even 5,000 jobs was an unsubstantiable exaggeration.
    5. In October, reporter Bob Mercer came to the same conclusion, saying EB-5 may have created hundreds of jobs.
  5. But, Bollen says, Mercer is a crazy liar. So is reporter Denise Ross. The press has simply made stuff up and destroyed EB-5:

The only "scandal" is that a fabulous economic development tool... has been decimated as a result of the political and media insanity that has prevailed in South Dakota over the last few months. I simply cannot imagine how the Regional Center can recuperate from the slew of negative press that has been published. This is especially true when so much of what has been published is inaccurate and misleading, such as Ms. Ross's articles in the Mitchell newspaper and Mr. mercer's articles in the Aberdeen American News. Many facts are either ignored or made up by these reporters [Joop Bollen, letter to Government Operations and Audit Committee, 2014.11.10, p. 1].

Uff da. Maybe we should just stand back and see what Mercer, Ross, and their editors have to say about that.

Bollen assumes the same tone with GOAC, accusing Senator Larry Lucas of similar malicious falsehood:

In addition to the misleading and inaccurate information carrying over into the polotical ads leading up to the November election, it has also carried over into the questions you pose to me. Many of them contain false assumptions of facts which are clearly politically driven. As I understand it, many of the questions were put together by Senator Lucas. I believe he derived most of his information/questions from bias [sic] allegations made by the plaintiff in the California matter, a plaintiff who ultimately was found to have no viable claims [Bollen, 2014.11.10, p. 2].

Bollen misfires here: most of the damning information about Bollen's and Mike Rounds's involvement with EB-5 in the Darley litigation comes not from anything plaintiff Robert Stratmore said but from things the Board of Regents, NSU counsel John Meyer, the arbitrator, Bollen's boon lawyer companion James Park, and Bollen himself said in the five-plus-year course of that litigation. (See also here, here, and here.)

And I haven't even gotten to his responses to GOAC's 75 questions yet. Stay tuned... and give Denise Ross and Bob Mercer wide berth.


Bob Mercer agrees that the EB-5 scandal is far from over. Next Thursday the Legislature's Government Operations and Audit Committee meets to discuss what went wrong in then-Governor, now Senator-Elect Mike Rounds's EB-5 visa investment program. GOAC chairman Senator Larry Tidemann (R-7/Brookings) has invited Board of Regents exec Jack Warner to talk about changes in the contract authorization process (which obviously broke down when EB-5 czar Joop Bollen wrote himself an illegal and lucrative private contract while working for the state).

The language Tidemann uses to invite Warner is different from the language he uses to invite Bollen. To Warner, Senator Tidemann says, "The Committee requests that you be present...." To Bollen, Senator Tidemann says, "I would like to request that you respond...." And while Warner, who has done little if anything wrong in the EB-5 mess other than not realizing Bollen was running a scam for himself and his friends from the NSU campus, is called to appear in person, Bollen is permitted leave to write a letter from his comfy home in Aberdeen.

Bollen is also allowed to miss deadlines. Senator Tidemann's September 30 request asked Bollen to reply by November 5 so that committee members would have time to review his response. They'll need that time: the September 30 letter includes 75 questions. Bollen could have written up three a day and still had plenty of time to finish, but GOAC still has no Bollen response on its agenda documents page. A knowledgeable source tells me that Bollen and his lawyer (that's EB-5 player Jeff Sveen) plan to respond on Monday, November 10.

Given Joop Bollen's willingness to lie to federal officials, we should probably not expect much. But we wait with bated breath for 75 repetitions of "I do not recall," "I decline to share confidential business information, " "I plead the Fifth," and maybe, just once, please, Joop, "Go ask Mike Rounds—it was his idea."


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