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SD EB-5 Liaison Starts in Korean Jail, Runs on No Contract, Illegal Lawyering

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.


  1. Bill Fleming 2014.10.19

    Okay, Cory, now the screenplay is coming together... ;-)

  2. mike from iowa 2014.10.19

    This already has Alan Smithee written all over it.

  3. Lanny V Stricherz 2014.10.19

    Damn, I sure wish that I had written this novel. It has more twists and turns than a Sherlock Holmes or a "Murder She Wrote" mystery.

  4. Lanny V Stricherz 2014.10.19

    Oh wait, it isn't fiction.

  5. grudznick 2014.10.19

    The best thing about this work of fiction is you libbies will be reading and gnashing about it for years. Years! The complete works of Jim Grant wouldn't keep you entertained as well.

  6. Jenny 2014.10.19

    I'm tellin' you guys, Charlie Sheen is made for the part of Joop.

  7. Jenny 2014.10.19

    What actor would make a good, dumb Mike Rounds character? Help me out here boys....

  8. mike from iowa 2014.10.19

    "Dutch" Raygun's memory is about as good as the lowlifes involved in this mess. He was a bad "B" grade actor and would be perfect for the entire cast since none of them remembers much.

  9. Lanny V Stricherz 2014.10.19

    The reason it is a work of fiction to you Grudz, is that if the devil him or her self were running, as long as they had an R behind their name, you would vote for them, no matter how corrupt, just like MMR and DD.

  10. Jenny 2014.10.19

    How about the short fat guy on Seinfeld playing Rounds?

  11. Tim 2014.10.19

    Jenny, do you have something against short fat guys?

  12. larry kurtz 2014.10.19

    William H. Macy plays Rounds, Javier Bardem plays Joop, Billy Bob Thorton as Benda.

  13. Jenny 2014.10.19

    No, not all. I'm sorry if I offended you. I'm just trying to think of an actor who could pull off the Mike Rounds character with a comedic touch to it. Sean Penn maybe? Someone in that age range with dark hair and slightly overweight. I know, maybe John Travolta?

  14. Jenny 2014.10.19

    William H Macy would be very funny as Rounds -remember Fargo? And Billy Bob Thornton is perfect as Benda! Thornton is good at playing twisted, disturbed characters.

  15. Bill Dithmer 2014.10.19

    Rounds ,Kelsey Grammer

    The Blindman

  16. Tim 2014.10.19

    Homer Simpson, the best Rounds.

  17. larry kurtz 2014.10.19

    Paula Deen as Linda Daugaard.

  18. larry kurtz 2014.10.19

    Kevin Spacey as Kevin Schieffer.

  19. larry kurtz 2014.10.19

    Jeff Goldblum as DD, the ghost of James Gandolfini as Dan Lederman.

  20. larry kurtz 2014.10.19

    Steve Buscemi in a fat suit as Jason Gant.

  21. grudznick 2014.10.19

    Shah Rukh Khan as Mr. kurtz. The older, chain smoking version.

  22. grudznick 2014.10.19

    No, Jabba the Hutt has union rights to play Mr. Gant.

  23. grudznick 2014.10.19

    Travolta would be perfect, Ms. Jenny, but he is too tall.

  24. Lanny V Stricherz 2014.10.19

    Vincent Price as DD and though I have never seen Grudz, Manny Steele as Grudz.

  25. grudznick 2014.10.19

    Yes, Mr. Steele is a much younger, less grizzled version of my manly visage.

  26. grudznick 2014.10.19

    I am fatter, though.

  27. Lanny V Stricherz 2014.10.19

    The picture in my mind of grudz just changed to Peter Lorie as the Hunchback of Notre Dame.

  28. mike from iowa 2014.10.19

    Peter Lorre and Steve Buscemi are twins.

  29. Richard Schriever 2014.10.19

    Wayne Knight is the guy who played NEWMAN!! on Seinfeld. He would make an excellent Rounds.

  30. lesliengland 2014.10.19

    geo. bush in a bomber jacket could play rounds

  31. scott 2014.10.19

    Steve Carrell can play Rounds, after he finishes the Mike Heuther bio pic.

  32. Jenny 2014.10.19

    I have a movie title - High Plains Corruption.

  33. Bill Fleming 2014.10.19

    Or 'High Plains Grifters'. :-)

  34. Roger Cornelius 2014.10.19

    grudz old buddy, the years you think the libbies will be talking about are actually the years Rounds, Bolen, Jackley and company will be serving in one of those luxury prison's for white collar crime, they probably wouldn't last too long in a North or South Korean prison.

  35. Roger Cornelius 2014.10.19

    You know I kind of like that idea of "illegal seminars" and getting thrown in prison for holding one.
    Take a hint South Dakota legislature, all seminars and meetings should be open to the public and if he you don't obey the police can come in and haul to the Sioux Falls prison. Sounds like a plan.

  36. grudznick 2014.10.19

    Mr. C, I think you and I could agree to build a compound somewhere, and yet it would remain empty for years and years. Could we agree it should be in Custer county?

  37. wal 2014.10.19

    Barney Fife can play one of them Gomer and Goober the other two

  38. Roger Cornelius 2014.10.19

    Sorry grudz,
    I'm really not to fond of Custer or Custer County, if you petition to change the name, I'll give it my strongest consideration.
    Otherwise, it can be anywhere, as it has bars and holds "political" prisoners.

  39. Roger Cornelius 2014.10.19

    Of late, whenever I read about Mike Rounds EB-5 Scandal, the music from "The Sting" starts playing in my head.

  40. lesliengland 2014.10.19

    Custer, Custer County or Custer State Park, is the NFL of South Dakota. The times they is a'changin...sing it grudz!

  41. Bill Dithmer 2014.10.19

    Didn't we do this before?

    Dicaprio as the mild mannered french teacher turned dirt digging blogger.

    Woody Haralson as bumbling dimwitted insurance man and former governor Smiling Mike Rounds.

    Dan Aykroyd as South Dakota’s present governor DD.

    David Spade as Joop Bollen.

    Robert Duvall as Dickie Benda

    John Caparulo as Attorney General Marty Jackley

    Tina Fey as Dr. Annette Bosworth

    Seth Rogen as Chad Haber

    Brian Bosworth as Stace Nelson

    Tom Selleck as Larry Rhoden

    Larry Pressler as Larry Pressler

    Kevin Nealon as Rick Weiland

    And Nick Nolte as the ghost of Bill Janklow. WTF

    The Blindman

  42. lesliengland 2014.10.19

    How about Lee? Whose gonna play intrepid reporter Lee Breitbart?? A young robert redford. :)))

  43. Deb Geelsdottir 2014.10.19

    Let's build a really small prison that will only hold about a dozen criminals. We can do it on the Republican Cheap, sort of a Sheriff Arpaio tent jail. Oh yeah, let's put it next to the lagoon at Potato Creek and let the folks there run it as they see fit.

  44. grudznick 2014.10.19

    Ms. Geelsdottir, you may have something there. Mr. H's friend Delon from Madison might even agree.

    Oh, and anything Blake Curd is for, you need to vote against. That means NO on IM 17

  45. tara volesky 2014.10.19

    Grudz, by saying no on 17 means you are for corporate takeover of health care.

  46. Deb Geelsdottir 2014.10.19

    I'm thinking about that $140 million that the people of SD were cheated out of. Seems like I've heard from Rick Weiland that there are 311 burgs in SD of all sizes, incorporated or not. My calculator says that if that money was divided up evenly, Mud Butte, Vale, Newell, and everywhere else, would have received $450,000 each. That would be pretty good for infrastructure, fire departments, garbage, parks, etc. I'm pretty sure they'd take it.

    How many public school districts are there in SD? 66? That comes out to $2 million a piece. Could your school district use a couple million bucks? It would be a godsend.

    How about putting that money into a scholarship fund for SD students at SD schools? Nice.

    $140,000,000 could do a lot for a small state like SD. All that possibility of good for all; and it disappeared with Rounds, Bollen and their criminal gang.

    (BTW, I am minimally capable at math, so feel free to correct my numbers. Thank you.)

  47. Deb Geelsdottir 2014.10.19

    Grudz my dear, what is 17?

  48. grudznick 2014.10.19

    It is the 5th prime number, Ms. Geelsdottir.

  49. JeniW 2014.10.19

    Deb, here is the link to all three of the ballot issues.

    Read the wording of IM 17 carefully. To me it is vaguely written, and if implemented only effects a select few. The buzzword word of "patient choice" is a buzzword.

    My concern is that I have not read whether anything like it has been implemented in any other state, and do not know the good, the not so good, and unintended consequences of it being implemented.

  50. Lanny V Stricherz 2014.10.19

    Jeni and Deb, I googled it but could not find if there are laws for choosing your own doctor. Yes on 17 has commercials that say 10 states have such laws. I saw the map but it was on so fast I could not see which states have such laws. The only two I identified immediately were Oregon and Idaho.

  51. Jenny 2014.10.19

    Dithmer, most of them are good choices! DiCaprio, Costner or even Rob Lowe would work for Mr Heidelberger - good guy working hard, fighting the corruption. You forgot Kathy Bates as Linda Daugaard. I think crazy scheming Glenn Close would play a better Bosworth. I don't know about Spade (too goodlooking) as Bollen. Selleck -excellet pick for the West River Rhoden cowboy.

  52. Jenny 2014.10.19

    I was thinking of another Spade actor. We need a real wormy actor as Bollen - very very corrupted and sociopathic. He's the main character after all. Depp would be convincing.

  53. Jenny 2014.10.19

    There will need to be a death in the first few minutes of the movie so I'm thinking Jack Nicholson as Bill Janklow hitting the motorcyclist and killing him. Nicholson (Janklow) pissed off more about his career than the death.

  54. Bree S 2014.10.19

    Will Ferrell as Joop Bollen.
    I second Billy Bob Thornton as Richard Benda.
    Gary Shandling as Mike Rounds.

  55. Deb Geelsdottir 2014.10.19

    Thanks for the link Jenny. I'll spend some time pondering it.

  56. tara volesky 2014.10.19

    Tom Cruse would do a nice job playing MMR.

  57. JeniW 2014.10.19

    I do not know why people are insulting all these fine actors by thinking they would play the role of Mike. LOL

  58. Roger Cornelius 2014.10.19

    Okay guys and gals, when we build this special prison for the South Dakota mafia, we have to make sure it is a for profit operation.
    Maybe we could get some EB-5 financing for it.

  59. Deb Geelsdottir 2014.10.20

    Hahaha! Great plan Roger! Shouldn't they be forced to do some menial labor? Break rocks, scrub restrooms, etc? Remember the Republican mantra, the market is more powerful than God and will fix everything. As you said, let's make sure money can be made on this deal. That means closely guarding expenses and minimizing outlay. Like I said earlier, Republican Cheap.

  60. lesliengland 2014.10.20

    cruz for rounds!! focus on the complexity, hokeyness of SD (better than FARGO), the survivor south dakotan culd be wismer (i kno shez a repub)

  61. Bill Fleming 2014.10.20

    Ha, great casting call, everybody. I like Ben Kingsly for Cory's part. And don't forget, the prison is already there... My alma mater cum federal penitentiary, Yankton College. That works well because Cory could go drive down and do interviews, and while there, drop in to visit a few State hospital inmates: Sibby, played by Christopher Walken, Annette Bosworth played by Angelina Jolie, and Lora Hubble played by Lora Hubble.

  62. lesliengland 2014.10.20

    that young guy, mike cera from "nick & norah's infinite playlist" could play cory, to bring in the youth gen!!

  63. lesliengland 2014.10.20

    christopher walken - hahahaha

  64. caheidelberger Post author | 2014.10.20

    Fascinating suggestions! I lean toward William H. Macy as Benda, Charlie Sheen as Joop (although Will Ferrell would bring the height and fun accent), Kevin Spacey as Jeff Sveen.

    I'd be thrilled to have Sir Ben play the interpid blogger... although Daniel Craig's turn in The Girl with the Dragon Tattoo could carry nicely to this role.

    Hey, how about Walken as Daugaard? Or Chris Cooper?

    Dang, there aren't enough good female roles in this script. How do we appeal to that half of the moviegoing market?

  65. Jane 2014.10.20

    No lawyer just "assists" without any interest financially or materially. Curious if they asked how much money they made and who shared the spoils. Also in order to bail out this NSU prof out of Korean Jail they would have used Governor connection to Korean authorities. Else there is no way that prof would have been released that easily.

  66. Jane 2014.10.20

    Folks these guys have made a mockery of SD citizens. Corruption of this scale and level would not happen in other states. No one has been arrested. Bollen is probably enjoying his fat life with his little bride, buying art. All the while thinking he will get away scott free and loaded.

  67. jerry 2014.10.20

    How about for Rounds, Stepin Fetchit

  68. Francis Schaffer 2014.10.20

    Where would we be now if the professor who helped Joop was from the other Korea?

  69. 96Tears 2014.10.20

    And dedicate the film to Bernie Madoff, the poor sap who's sitting in prison while the S.D. Republican Party supports racketeers to serve in the U.S. Senate.

  70. Lanny V Stricherz 2014.10.20

    96, You just hit on the part of this fiasco, that is the most saddening.

  71. mike from iowa 2014.10.20

    This movie would cost more in "star" salaries than what it cost to get NBP to fail.

  72. Roger Elgersma 2014.10.20

    In a small rural town a handshake meant something. It meant honesty. So Bill Janklow twisted the honest impression of a handshake into a deal that no one could ever find a paper trail for. Now comes an immigrant, Joop, and sees the culture or lack thereof in South Dakota handshakes and continues the fiasco that he learned here.

  73. Jenny 2014.10.20

    That's true, Mike, we would have to narrow it down to only one or two big name actors, since they demand so much money.

  74. mike from iowa 2014.10.20

    On the bright side-no cattle would have to be killed to make this movie realistic,would they? Did NBP actually process any?

  75. Steve Sibson 2014.10.20

    So is this thread about EB-5 or about making movies?

  76. Susan 2014.10.20

    I don't know of any attorney who would help somebody file a pro se pleading in a lawsuit against a state. Appears that Hanul Law also no longer exists, but there is a new firm in the same location with James Park but a different name. Wonder why the name change.

  77. Roger Cornelius 2014.10.20

    Sibson, this thread is about how to write your own blog.

  78. john tsitrian 2014.10.20

    Ryan, how do I get a transcript of this?

  79. Bill Fleming 2014.10.20

    John, if no transcript is available, you may be able to make your own with an app like this. Might need to use two divides... your mac or PC and your iPhone for example. Play the audio on your desk machine while recording it on your iPhone app. Looks like then it will automatically transcribe it, and you could save it and print it out. Might work. Haven't tried it tho.

  80. Bill Fleming 2014.10.20

    Might need to use two DEVICES....

  81. john tsitrian 2014.10.20

    Thanks Bill. I'll see if we can make it work. I'll be in Rapid for a few days starting tomorrow, so if you know of a hard copy floating around, I'd sure like to take a long look at it.

  82. Bill Dithmer 2014.10.20

    Bill, I think what John wants is a free program called "Audacity." I did it a couple of years ago but cant remember what was involved but I did make a hard copy without much trouble.

    The Blindman

  83. Jane 2014.10.20

    It appears that some of the bloggers want to joke and distract from the real issue. Take it to Joopster's house folks, I challenge you to get the actual scoope. Joopster probably has a IP - intellectual property patent out on his story by now, and Park prob filed it pro bono.

  84. Deb Geelsdottir 2014.10.20

    Christopher Walken in the Sibson role? Hahahahahahahaha!!!
    Or the guy who played the scientist in Back to the Future! Bwahahaha!

    (Jane, there is nothing wrong with a little light-hearted humor. There is plenty of serious work going on here too. Both exist simultaneously.)

  85. Deb Geelsdottir 2014.10.20

    Of, I looked him up. Christopher LLOYD! He's the one!

  86. caheidelberger Post author | 2014.10.20

    Jane, I'm still working. But after grinding through all those depositions this weekend, I'm glad my friends can provide some comic relief.

  87. Jane 2014.10.20

    That comic relief gave me some energy.....let's see how much laughter this will give us.
    This article speaks of Hanul Law Firm established in 1985. In 2002 they created a division Immigration & Foreign Law Group'( to specialize in the EB-5 in contract with the regional center in South Dakota. This Regional Center was run by the State Government which assured its clients, and that they had exclusive permission. There were many fraudulent programs around and this particular relationship would provide security.
    (Loosely translated! But I got the jest).
    This site is so minimal, not sure what happened.
    Found James Park listed on the attorneys list.
    This office is registered Su Ki Kim, President.
    Su Ki Kim is aka Austin Kim.
    H & H, a Professional Law Corporation.
    James Park, President of Hanul Law Corporation.

  88. Jane 2014.10.20

    Cory you have my utmost respect.

  89. lesliengland 2014.10.20

    very good duffy press conf. thx

  90. lesliengland 2014.10.20

    well, i don't mean to suggest anything, but since someone mentioned the flic is lite on chix, cherri brick could be played by....

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