According to Brent Raymond, Vermont Regional Center
director, a memorandum of understanding in September 2012 was canceled because
the parameters of the American Dream Fund's Dreamlife project had changed from
those initially approved. Since then, Dreamlife spokesman Phil Mooney took the
role of head of the consortium, in place of Richard Parenteau. Mooney's
excellent background and record and various reassurances convinced Vermont to
be comfortable with reinstating the project. Thus, a new memorandum of
understanding in November 2012 was born of the rebuttal of this first
cancellation. However, this November memorandum of understanding has also been

Lawrence Miller, the Secretary of Commerce, has pointed out
various problems with the project and materials of misrepresentation. The
project proposed the building of 10 homes for assisted living in Vermont. Under
the plan, the project was going to use $160 million in EB-5 investment and
create over 3,000 jobs. The only other EB-5 project in Vermont bigger than this
would have been Jay Peak.  

According to Miller, the number of issues and questions the Vermont
Regional Center had about the American Dream Fund's project kept increasing.
For example, American Dream Fund incorrectly identified USMS Team, LLC., limited
liability corporation located in Florida, as the legal counsel for the project.
In reality, USMS does not have a license to practice law in the state of
Florida. The fact that the American Dream Fund represented to Vermont that USMS
Team, LLC. was a law firm that was going to ensure that the Dreamlife project
was in compliance with U.S. law regarding the EB-5 Visa Program is a breach of
the memorandum of understanding.

Additionally, American Dream Fund listed three professionals
and claimed that they were a part of the Dream Life Project Team in marketing
materials posted on the project's website. These trade professionals included
Carl Childs, a structural engineer, Thomas Leytham, an architect, and Edward
Pearson, from Pearson & Associates. According to Miller, the three
professionals were not aware that American Dream Fund had listed them as being
on the project. Miller also cited that, while aboard, Mooney directed potential
investors to the project's website where these misrepresentations existed.

Thus, on March 27th, the memorandum of
understanding from November, between the American Dream Fund I, LLC., the Agency
of Commerce and Community Development, was canceled by Miller. Since then,
Mooney has claimed that Dreamlife was completely transparent and open about the
project. According to Mooney, he repeatedly notified Raymond that USMS was not
a law firm. He also claims that he has a copy of a letter between Leytham and
Miller, dated March 29th, explaining that Leytham did know his name
was on the project's website. He also says he has a copy of an email from
Childs who was not against having his name in the website materials.
Supposedly, Childs agreed to be named in the project but did not guarantee that
he would have time to work on the project once it started.  

Dreamlife is the first EB-5 project to not move forward in
the state of Vermont. For more information on the EB-5 Program and information
about Regional Centers, please visit