"Oversight Letter and Subpoena to SBA Administrator Guzman Regarding Voter Registration Activities"

Summary

Letter dated July 30, 2024 from Roger Williams, Chairman of the House Committee on Small Business, to SBA Administrator Isabella Casillas Guzman, with an attached subpoena for documents. The letter states that the Committee is investigating the SBA's implementation of Executive Order 14019 and its Memorandum of Understanding with the Michigan Department of State designating the SBA as a Voter Registration Agency in Michigan. It says the SBA has provided only 359 pages of largely duplicative documents in four months and recounts the Committee's letters, interviews and hearings from April 4, 2024 onward. The subpoena, issued under Rule XI.2(m)(1)(B) of the House Rules, commands production of documents on August 13, 2024. Its schedule lists SBA communications regarding EO 14019 and the MOU from March 7, 2021 to present, implementation plans and official calendar entries.
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Full text

ROGER WILLIAMS, Texas NYDIA M. VELAZQUEZ, New York

CHAIRMAN RANKING MEMBER

Congress of the Wnited States

LS. House of Representatives

Committee on Small Business
230) Ranburn Wovse Office Building
Washington, HE 20515-0515

July 30, 2024

The Honorable Isabella Casillas Guzman
Administrator

U.S. Small Business Administration

409 3rd Street SW

Washington, DC 20416

Dear Administrator Guzman:

The House Committee on Small Business (Committee) is investigating the Small
Business Administration’s (SBA) implementation of Executive Order (EO) 14019 and its related
Memorandum of Understanding and Memorandum of Agreement (collectively, the MOU) with
the Michigan Department of State (MDOS), which designated the SBA as a Voter Registration
Agency in the State of Michigan under the National Voter Registration Act (NVRA). The
purpose of this investigation is to evaluate legislative solutions to the SBA’s use of federal funds
to conduct voter registration activities. Unfortunately, the SBA has produced only a small
portion of the documents and communications that the Committee has requested and has done so
slowly and after multiple attempts by the Committee to obtain any relevant information. Indeed,
in response to the Committee request for all documents and communications related to the MOU,
the SBA has only provided 359 pages of largely duplicative documents in the four months since
this investigation began. The SBA’s continual obstruction has hindered the Committee’s ability
to consider legislative reforms needed to ensure the integrity of the 2024 elections and equal
access to the ballot box for all Americans.

The Committee first learned of the MOU between the SBA and MDOS on March 19,
2024. The following day, the Committee held a hearing with you entitled, “Conducting
Oversight: Testimony from the Small Business Administrator.” During this hearing,
Representative Dan Meuser requested the following documents related to the SBA’s
implementation of EO 14019 and its MOU with Michigan: (1) every email and official
correspondence between the SBA and businesses related to this MOU; and (2) every email and
official correspondence between the SBA and other government agencies related to this MOU.!
You indicated that you would “put in that request with my team and follow up with [Rep.
Meuser] directly.”? Congressman Meuser has yet to hear back from you.

' See Conducting Oversight: Testimony from the Small Business Administrator: Hearing Before H. Comm. on Small
Bus., 118th Cong. (Mar. 20, 2024) (statement of Dan Meuser, Member, H. Comm. on Smali Bus.).
2 Id.
The Honorable Isabella Casillas Guzman
July 30, 2024
Page 2 of 4

On April 4, 2024, the Committee sent the SBA the first of its many letters on this issue,
seeking the information initially requested during the hearing, as well as additional documents
and information on the nature and background of the MOU.

On April 17, 2024, a video emerged of an SBA political appointee, Tyler Robinson,
discussing how the SBA is supporting the reelection campaign of President Joe Biden and
Congressional Democrats. The next day, the Committee requested that the SBA make Mr.
Robinson and his supervisor, SBA Chief of Staff Arthur Plews, available for transcribed
interviews in early May.° The SBA declined to make any of its employees available for
interviews, instead offering to brief the Committee on the MOU. The Committee accepted the
briefing, which took place on May 3. However, when Committee staff attempted to ask questions
about the video and the allegations contained therein, the SBA shut down the questioning. When
Committee staff asked questions about the briefer’s role at the SBA and her experience with
voter registration, SBA staff again shut down the questions. And when the Committee asked
where it could find more information on the SBA’s events and your travel related to this MOU,
the SBA directed the Committee to the SBA’s X account. Given the SBA’s lack of transparency
during the briefing—not to mention its unseriousness in directing a Congressional Committee to
check a public social media platform for oversight purposes—the Committee must now
subpoena the documents it requested to conduct effective oversight of the SBA and its activities.

Additionally, because the SBA refused to make Mr. Robinson and Mr. Plews available
for voluntary interviews, the Committee issued its first two subpoenas in more than a decade,
compelling their appearances at depositions.® At the SBA’s request, and in an effort to work with
the SBA in good faith, the Committee made the extraordinary accommodation of allowing Mr.
Robinson and Mr. Plews to appear voluntarily for transcribed interviews instead of depositions.
These interviews took place on June 4 and June 11, respectively. Unfortunately, these individuals
conveniently could not recall key information. For example, during Mr. Plews’s transcribed
interview, he claimed nearly 200 times that he lacked awareness or knowledge of relevant facts
related to this investigation.’ In the face of the apparently faulty memory of SBA’s political
appointees, the Committee’s need for the requested documents became much more pressing.

After multiple phone conversations, on May 10, 2024, the SBA finally provided a
complete copy of the MOU, as well as a three-page slide deck from the May 3, 2024 briefing.® In

3 Letter from Roger Williams, et al., Chairman, H. Comm. on Small Bus., to Isabella C. Guzman, Adm’r, U.S. Small
Bus. Admin. (Apr. 4, 2024).

* James O’ Keefe (@JamesOKeefelll), X (Apr. 17, 2024, 3:57 PM),

https://x.com/JamesOK eefelII/status/ 1780687 148527579215.

> Letter from Roger Williams, et al., Chairman, H. Comm. on Small Bus., to Isabella C. Guzman, Adm’r, U.S. Small
Bus. Admin, (Apr. 18, 2024),

® Subpoena from Roger Williams, et al., Chairman, H. Comm. on Small Bus., to Tyler Robinson, Special Advisor,
U.S. Small Bus. Admin. (May 7, 2024); Subpoena from Roger Williams, et al., Chairman, H. Comm. on Small Bus.,
to Artur Plews, Chief of Staff, U.S. Small Bus. Admin. (May 7, 2024).

7 Transcribed Interview of Mr. Arthur Plews, Chief of Staff, U.S. Small Bus. Admin., conducted by the House
Comm. on Small Bus. (Jul. 22, 2024),

8 See Letter from George Holman, Assoc. Adm’r, Cong. and Legislative Affairs, U.S. Small Bus. Admin., to Roger
Williams, Chairman, H. Comm. on Small Bus. (May 10, 2024).
The Honorable Isabella Casillas Guzman
July 30, 2024
Page 3 of 4

total, this production amounted to just 17 pages of documents and contained zero
communications responsive to the Committee’s requests. On May 29, 2024, the SBA produced
156 pages of emails between the SBA and MDOS about the drafting process of this MOU, many
of which were largely duplicative.? The May 29 production included incomplete email
exchanges with abrupt, protracted gaps between when these exchanges occurred, clearly
implying that additional relevant communications exist outside of what was provided to the
Committee.

On May 16, 2024, the Committee sent a joint letter with the Ranking Member of the
Senate Committee on Small Business and Entrepreneurship, Senator Joni Ernst, to the SBA
seeking the calendars and travel itineraries for 11 identified SBA employees and any trip
summaries, transcripts, or any related documents memorializing reimbursements for the travel
and trips.!° On June 14, 2024, the SBA provided 49 different media advisories announcing
events from March 2023 through May 2024 but no substantive communications.'! Notably, the
SBA did not provide calendars or itineraries for any of its employees, nor did it provide any
summaries or transcripts of events. Worse yet, as the Committee informed the SBA at the time,
the production was not responsive to any of the Committee’s requests.

On June 27, 2024, the Committee and staff for Ranking Member Ernst met with the SBA
to discuss the status of the outstanding document requests. During this meeting, the Committee
agreed to multiple accommodations to help the SBA expedite the production of documents. The
SBA indicated that the Committee and Ranking Member Emst could expect documents to be
produced “in July” and on a rolling basis going forward. On July 2, 2024, the SBA produced one
document that it claimed was responsive to the Committee’s April 4, 2024 and April 18, 2024
letters: a single email chain between SBA and MDOS, which was repeated over 97 pages, the
majority of which concerned the logistics behind announcing the MOU." Given that this
production also included incomplete email exchanges with abrupt, protracted gaps between when
exchanges occurred, it is clear that there are emails responsive to Committee’s requests that the
SBA has not yet produced to the Committee.

After giving the SBA time to comply with these requests and making numerous
accommodations as to the prioritization and scope of the requests, the Committee and Ranking
Member Ernst sent a follow-up letter to the SBA on July 15, 2024, reiterating their outstanding
requests and memorializing the prioritization of documents.'? The Committee also identified 20

° See Letter from George Holman, Assoc. Adm’r, Cong. and Legislative Affairs, U.S. Small Bus. Admin., to Roger
Williams, Chairman, H. Comm. on Small Bus. (May 29, 2024).

'° Letter from Roger Williams, Chairman, H. Comm. on Small Bus., and Joni Ernst, Ranking Member, S. Comm. on
Small Bus. and Entrepreneurship, to Isabeila C. Guzman, Adm’r, U.S. Small Bus. Admin. (May 16, 2024).

! See Letter from George Holman, Assoc. Adm’r, Cong. and Legislative Affairs, U.S. Small Bus. Admin., to Roger
Williams, Chairman, H. Comm. on Small Bus., and Joni Ernst, Ranking Member, S$. Comm. On Small Bus. and
Entrepreneurship (June 14, 2024).

See Letter from George Holman, Assoc. Adm’r, Cong. and Legislative Affairs, U.S. Smali Bus. Admin., to Roger
Williams, Chairman, H. Comm. on Small Bus. (Jul. 2, 2024),

'5 Letter from Roger Williams, Chairman, H. Comm. on Small Bus., and Joni Ernst, Ranking Member, S. Comm.
On Small Bus. and Entrepreneurship, to Isabella C. Guzman, Adm’r, U.S. Small Bus. Admin. (Jul. 15, 2024).
The Honorable Isabella Casillas Guzman
July 30, 2024
Page 4 of 4

SBA employees for whom SBA should prioritize the production. On July 29, 2024, the SBA
produced two messages from the same email chain as prior productions, both of which can be
found no less than eight times in the July 2, 2024, production, but provided no other responsive
documents.

Moreover, on July 24, 2024, the Committee held a hearing entitled, “Examining the
SBA’s Electioneering Efforts with Associate Administrator Jennifer Kim.” During this hearing,
Ms. Kim showed a severe lack of awareness regarding how this MOU came to be and how it
would be implemented, even though she signed the MOU and was the SBA’s Associate
Administrator of the Office of Field Operations, which is responsible for implementing this
MOU. Given that the Committee is unable to obtain the information it needs from the person
most responsible for this MOU, a documents subpoena is necessary to obtain this information.

The SBA continues to obstruct the Committee’s legislative efforts. Though the
Committee appreciates that the SBA made two of its political appointees available for
interviews, the SBA did so only after the Committee compelled their appearances. The minimal
information provided in those interviews and the paltry document production so far has not
satisfied the Committee’s legislative need for the requested communications surrounding the
decision. The Committee still has not seen a substantial number of communications surrounding
this MOU, the calendars of SBA employees involved in this MOU, or the implementation plan(s)
for this MOU. Nor has the SBA provided sufficient evidence to show how this agreement came
to be. These communications and documents are critical to assessing how and why this
agreement was made in the first place and how it is being implemented.

The Committee has broad authority to investigate “problems of all types of small
business” under House Rule X.3(/). The Committee continues to have serious concerns regarding
the SBA’s efforts to comply with legitimate oversight requests and will not tolerate any further
delay. Accordingly, attached to this letter is a subpoena, issued pursuant to Rule XI.2(m)(1)(B)
of the Rules of the House of Representatives and Rule 9(A) of the Committee’s rules.

Sincerely,

/) OS ° —
"Roger Williams

Chairman
House Committee on Small Business

ce: The Honorable Nydia M. Velazquez, Ranking Member
SUBPOENA

BY AUTHORITY OF THE HOUSE OF REPRESENTATIVES OF THE
CONGRESS OF THE UNITED STATES OF AMERICA

The Honorable Isabella Casillas Guzman, Administrator of the U.S. Small Business Administration
To

You are hereby commanded to be and appear before the
House Committee on Smail Business

of the House of Representatives of the United States at the place, date, and time specified below.

to produce the things identified on the attached schedule touching matters of inquiry committed to said
committee or subcommittee; and you are not to depart without leave of said committee or subcommittee. .

Place of production: 2361 Rayburn House Office Building, Washington, D.C. 20515

Date: August 13, 2024 Time: 12:00p.m.

[_] _ to testify at a deposition touching matters of inquiry committed to said committee or subcommittee;
and you are not to depart without leave of said committee or subcommittee.

Place of testimony:

Date: Time:

[] to testify at a hearing touching matters of inquiry committed to said committee or subcommittee; and
you are not to depart without leave of said committee or subcommittee.

Place of testimony:

Date: Time:

To any authorized staff member or the U.S. Marshals Service

to serve and make return.

Witness my hand and the seal of the House of keprgsentatives of the Unjtéd States, at

the city of Washington, D.C. this 39

Attest:

PoP erk
Schedule to Subpoena

In accordance with the attached Schedule instructions, you, Isabella Casillas Guzman,

Administrator of the U.S. Small Business Administration (SBA), are required to produce the
following items in your possession, custody, or control in unredacted form:

1.

All communications, including Microsoft Teams messages, between and among SBA
personnel regarding Executive Order (EO) 14019, voter registration, access to voting,
and/or the Memorandum of Understanding or Memorandum of Agreement (collectively,
MOU), from March 7, 2021 to present, as well as the search terms the SBA used to
identify these communications.

All communications between SBA personnel and third parties, including but not limited
to small business owners, associations, non-profits, and SBA resource partners in the
State of Michigan, regarding EO 14019, and/or the MOU, from March 7, 2021, to
present, as well as the search terms the SBA used to identify these communications.

The implementation plans regarding this MOU.

Interim and final reports drafted and submitted to the White House regarding
implementation of EO 14019.

Documents sufficient to show whether the SBA engaged in any activity relating to voter
access or voter registration prior to the March 19, 2024 announcement of the MOU.

Documents sufficient to show whether the SBA or the Michigan Department of State
initiated the engagement on the MOU.

The official calendar entries for the following individuals from June 1, 2022, through
December 31, 2024:

Julie Verratti (up until she departed SBA)

Scott Harriford (up until he departed SBA)

The SBA individual appointed as the Michigan National Voter Registration Act
of 1993 (NVRA) coordinator.

a. Isabella Casillas Guzman
b. Dilawar Syed

c. Arthur Plews

d. Jennifer Kim

e. Victor Parker

f. Destine Hicks

g. Geri Sanchez Aglipay
h. Laketa Henderson

i.

j.

k.
8. All travel itineraries for official trips the following individuals have taken, and are
currently scheduled to take in the future, including where, when, and with whom, from
March 1, 2024, through December 31, 2024:

Isabella Casillas Guzman

Dilawar Syed

Arthur Plews

Jennifer Kim

Victor Parker

Destine Hicks

Geri Sanchez Aglipay

Laketa Henderson

Julie Verratti (up until she departed SBA)
Scott Harriford (up until he departed SBA)
The SBA individual appointed as the Michigan National Voter Registration
Act of 1993 (NVRA) coordinator.

roo mo Bo op

9. Documents sufficient to show any reimbursement for costs associated with political
activities under the Hatch Act, including all reimbursement statements, for all trips
encompassed in requests 7 and 8 of this schedule, as well as the search terms the SBA
used to identify these documents.

10. All transcripts of remarks made by SBA personnel on trips encompassed in requests 7
and 8 of this schedule.
RESPONDING TO THE COMMITTEE’S SUBPOENA

In responding to this Subpoena, please apply the instructions and definitions set
forth below:

INSTRUCTIONS

1. In complying with this Subpoena, you are required to produce all responsive documents
in unredacted form that are in your possession, custody, or contro! or otherwise available
to you, regardless of whether the documents are possessed directly by you. You are also
required to produce documents that you have a legal right to obtain, that you have a right
to copy or to which you have access, as well as documents that you have placed in the
temporary possession, custody, or control of any third party. You must also produce any
responsive documents or communications from any Slack or Teams channel that you
own, is in your primary control, or have access to. Subpoenaed records, documents, data,
or information should not be destroyed, modified, removed, transferred, or otherwise
made inaccessible to the Committee.

2. In the event that any entity, organization, or individual named in the Subpoena has been,
or is currently, known by any other name, the Subpoena should be read also to include
such other names under that alternative identification.

3. The Committee's preference is to receive documents in electronic form in lieu of paper
productions.

4. Documents produced in electronic format should also be organized, identified, and
indexed electronically.

5. Documents produced to the Committee should include an index describing the contents of
the production. To the extent that more than one CD, hard drive, memory stick, thumb
drive, box, or folder is produced, each CD, hard drive, memory stick, thumb drive, box, or
folder should contain an index describing its contents.

6. When you produce documents, you should identify the paragraph(s) and/or clause(s) in
the Committee’s schedule to which the documents respond.

7. Documents produced pursuant to this Subpoena should be produced in the order in which
they appear in your files and should not be rearranged. Any documents that are stapled,
clipped, or otherwise fastened together should not be separated.

8. Documents produced in response to this Subpoena should be produced together with
copies of file labels, dividers, or identifying markers with which they were associated
when this Subpoena was issued. Indicate the office or division and person from whose
files each document was produced.

9. It shall not be a basis for refusal to produce documents that any other person or entity
also possesses non-identical or identical copies of the same documents.

3
10.

ll.

12.

13.

14.

15.

16.

17.

18.

If any of the subpoenaed information is only reasonably available in machine-readable
form (such as on a computer server, hard drive, or computer backup tape), you should
consult with Committee staff to determine the appropriate format in which to produce
the information.

If compliance with the Subpoena cannot be made in full by August 13, 2024, at 12:00
PM EDT, compliance shall be made to the extent possible by that date. An explanation
of why full compliance ts not possible shall be provided no later than August 6, 2024, at
12:00 PM EDT.

In the event that a document is withheld on any basis, provide a log containing the
following information: (a) the basis for withholding the document; (b) the type of
document; (c) the general subject matter; (d) the date, author, and addressee; and (e) the
relationship of the author and addressee to each other.

If any document responsive to this Subpoena was, but no longer is, in your possession,
custody, or control, or has been placed into the possession, custody, or control of any
third party and cannot be provided in response to this Subpoena, you should identify the
document (stating its date, author, subject, and recipients) and explain the circumstances
under which the document ceased to be in your possession, custody, or control, or was
placed in the possession, custody, or control of a third party.

In complying with the Subpoena, be apprised that the U.S. House of Representatives and
the Committee do not recognize any purported non-disclosure privileges associated with
the common law including, but not limited to, the deliberative process privilege, the
attorney-client privilege, and attorney work product protections; any purported
privileges or protection from disclosure under the Freedom of Information Act; or any
purported contractual privileges, such as non-disclosures agreements.

If any document responsive to this Subpoena cannot be located, describe with particularity
the efforts made to locate the document and the specific reason for its disappearance,
destruction, or unavailability.

If a date or other descriptive detail set forth in this Subpoena referring to a document,
communication, meeting, or other event is inaccurate, but the actual date or other
descriptive detail is known to you or is otherwise apparent from the context of the
Subpoena, you should produce all documents which would be responsive as if the date or
other descriptive detail were correct.

The Subpoena is continuing in nature and applies to any newly discovered document,
regardless of the date of its creation. Any document not produced because it has not
been located or discovered by the return date should be produced immediately upon
location or discovery subsequent thereto.

All documents should be Bates-stamped sequentially and produced sequentially.
19. Two sets of the documents should be delivered to the Committee, one set to the Majority
staff in Room 2361 of the Rayburn House Office Building and one set to the Minority
staff in Room 2069 of the Rayburn House Office Building. You should consult with
Committee staff regarding the method of delivery prior to sending any materials.

20. Upon completion of the document production, you must submit a written certification,
signed by you or your counsel, stating that: (1) a diligent search has been completed of all
documents in your possession, custody, or control that reasonably could contain
responsive documents; (2) all documents located during the search that are responsive
have been produced to the Committee.
1.

DEFINITIONS

The term “document” means any written, recorded, or graphic matter of any nature
whatsoever, regardless of how recorded, and whether original or copy, including, but not
limited to, the following: memoranda, reports, expense reports, books, manuals,
instructions, financial reports, working papers, records, notes, letters, notices,
confirmations, telegrams, receipts, appraisals, pamphlets, magazines, newspapers,
prospectuses, interoffice and intra-office communications, electronic mail (“email”),
instant messages, calendars, contracts, cables, notations of any type of conversation,
telephone call, meeting or other communication, bulletins, printed matter, computer
printouts, invoices, transcripts, diaries, analyses, returns, summaries, minutes, bills,
accounts, estimates, projections, comparisons, messages, correspondence, press releases,
circulars, financial statements, reviews, opinions, offers, studies and investigations,
questionnaires and surveys, presentations, spreadsheets, and worksheets (and all drafts,
preliminary versions, alterations, modifications, revisions, changes, and amendments to
any of the foregoing as well as any attachments thereto), and other written, printed, typed,
or other graphic or recorded matter of any kind or nature, however produced or
reproduced, and whether preserved in writing, film, tape, disk, videotape, or otherwise. A
document bearing any notation not part of the original text is to be considered a separate
document. A draft or non-identical copy is a separate document within the meaning of this
term.

The term “communication” means each manner or means of disclosure or exchange of
information, regardless of means utilized, whether oral, electronic, by document or
otherwise and whether in a meeting, by telephone, facsimile, email, text message, instant
message, MMS or SMS message, regular mail, telexes, releases, or otherwise.

The term “calendar” means any document, tool, device, or other means used to track or
organize the events and schedule of an individual or group. This includes both electronic
calendar records and paper calendar records.

The phrase “possession, custody, or control” means (a) documents that are in your
possession, custody, or control, whether held by you or your past or present agents,
employees, or representatives acting on your behalf; (b) documents that you have a legal
right to obtain, that you have a right to copy, or to which you have access; and (c)
documents that have been placed in the possession, custody, or control of any third party.

The terms “and” and “or” should be construed broadly and either conjunctively or
disjunctively as necessary to bring within the scope of this Subpoena any information which
might otherwise be construed to be outside its scope. The singular includes the plural number
and vice versa. The masculine includes the feminine and neuter genders.

The terms “person” or “persons” mean natural persons, firms, partnerships, associations,
limited liability corporations and companies, limited liability partnerships, corporations,
subsidiaries, divisions, departments, joint ventures, proprietorships, syndicates, other legal,
business or government entities, or any other organization or group of persons, and all
subsidiaries, affiliates, divisions, departments, branches, and other units thereof.

6
10.

11.

12,

13,

14.

15.

16.

17.

The terms “referring” or “relating,” with respect to any given subject, mean anything that
constitutes, contains, embodies, reflects, identifies, states, refers to, deals with, or is in any
manner whatsoever pertinent to that subject.

The term “employee” means agent, borrowed employee, casual employee, consultant, de
facto employee, joint adventurer, loaned employee, part-time employee, permanent
employee, provisional employee, contract employee, contractor, or any other type of
service provider.

The acronym “MDOS” refers to the Michigan Department of State.
The acronym “SBA” refers to the U.S. Small Business Administration.

The term “EO 14019” means President Joseph R. Biden’s Executive Order 14019—
Promoting Access to Voting.

The acronym “MOU” refers to both the SBA’s Memorandum of Understanding with MDOS
designating the SBA as a voter registration agency and the related Memorandum of
Agreement with MDOS.

The term “implementation plan” refers to any documents, communications, policies, or
procedures which direct the SBA and its employees on how it will prepare for and perform
its duties under the MOU. This includes, but is not limited to: Standard Operating
Procedures, policy documents, employee training plans or schedules, instruction documents,
or any other document which explains how the SBA will implement its MOU with
Michigan or how employees should behave under this MOU.

The term “existing transcript” means any record, written document, or audio recording of
the remarks of a speaker, which is presently available or for which the SBA would not have
to create a new transcript.

The term “official calendar entries” refers to calendar entries maintained as part of the
SBA’s official government work and the official duties of its employees.

The term “trip summary” refers to any document created concurrently or after an individual
travels that would record what occurred on the trip. This can include summaries of financial
expenditures, documentation of meetings and attendees, catalogs of actions taken during the
employee’s travel, or any other document that describes the activities of SBA employees
while on official travel.

The phrase “evidence sufficient to show” refers to documents that would prove the
affirmative allegation or that would suggest that the negative allegation is correct. It may not
be possible to provide a document which affirmatively shows that SBA was uninvolved in
some specific activity; in that case, documents that suggest SBA took an alternative course
of action are sufficient.
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