Gaming Commission Ordinance
Ordinance # 04-400-04

Article I.  Purpose; Findings

1.01. 	Purpose.  The Tribal Council of the Little River Band enacts this Ordinance for the purposes of creating a regulatory agency to carry out licensing and oversight responsibilities regarding gaming  governed by the Gaming Ordinance, # 010-400-01, and as may be directed in this Ordinance.

1.02.  	Findings.  The Tribal Council of the Little River Band of Ottawa Indians finds that:

a.  	The Constitution of the Little River Band of Ottawa Indians delegates to the Tribal Council the responsibility to “...exercise the inherent powers of the Little River Band by establishing laws through the enactment of ordinances and adoption of resolutions not inconsistent with this Constitution:

1. 	To govern the conduct of members of the Little River Band and other persons within its jurisdiction;

2. 	To promote, protect and provide for public health, peace, morals, education and general welfare of the Little River Band and its members[.]” Article IV, Section 7(a).

b.  	The regulation and licensing of gaming is an important regulatory function that can be best carried out through the creation of a regulatory commission by a separate Ordinance under authority of the Little River Band of Ottawa Indians Constitution, Article IV, Section 7(f).

Article II.  Adoption; Amendment; Repeal; Severability

2.01.  	Adoption.  This Ordinance is adopted by the Tribal Council through Resolution # 02-0508-09.

a.  	Amended by Resolution # 05-0406-135 - regarding removal of management contract references and coordinating definitions with the Gaming Ordinance.

b. 	Amended by Resolution # 06-0621-420 - increasing the number of members from three to five.

c. 	Emergency Amendments by Resolution # 08-0826-274 – allowing for a variation in the number of Commissioners from no less than three (3) to no more than five (5) and establishing that a quorum consists of the majority of duly appointed Commissioners remaining on the Commission; establishing mandatory appointment when there are less than three (3) sitting Gaming Commissioners.

d.  	Permanent adoption of emergency amendments by Resolution #09-0121-23.

e.	Amended by Resolution # 19-0327-072 - updating the Ordinance to address Commissioner status, correcting grammar, and resolving formatting issues.

f.	Amended by Resolution # 20-0205-044 - requiring all Commissioners are Tribal Members and lowering the age limit for Commissioners to eighteen (18).

g.	Amended by Resolution #20-____-___ requiring the Gaming Commission to create employment policies for Commission staff.

2.02.  	Amendment.  This Ordinance may be amended from time to time as set forth in the Constitution or in procedures adopted by the Tribal Council.

2.03. 	Repeal. This Ordinance may be repealed in accordance with the procedures set forth in the Administrative Procedures Act – Ordinance.

2.04.  	Severability.  If any provision of this Ordinance or its application to any person or circumstance is held invalid, the invalidity does not affect other provisions or applications of this Ordinance which can be given effect without the invalid provision or application, and to this end the provisions of this Ordinance are severable.

Article III.  Definitions

3.01.  	General.  In this Ordinance, except where otherwise specifically provided or the context otherwise requires, or as may be defined in the Gaming Ordinance #10-400-01, the following terms and expressions shall have the following meanings.

3.02. 	Commission means the Gaming Commission as created in this Ordinance, with the powers and authority vested therein pursuant to this Ordinance.

3.03. 	Commissioner means a member of the Gaming Commission.

Article IV. Creation of Gaming Commission

4.01.  	Establishment.  The Tribal Council hereby creates a Gaming Commission as the regulatory agency of the Tribe to carry out licensing and oversight responsibilities regarding gaming governed by the Gaming Ordinance, # 010-400-01. The Gaming Commission is delegated the right to exercise one or more of the substantial governmental functions of the Tribe as defined in this Ordinance. In creating the Gaming Commission, it is the purpose and intent of the Tribal Council that the Gaming Commission ensure the integrity, honesty and fairness of all gaming activities conducted on the Tribe's Reservation and that such gaming activities be conducted in conformance with the Tribal-State  Compact, Gaming Ordinance #10-400-01, this Ordinance, Federal, applicable State and Tribal laws, and any regulations promulgated by the Gaming Commission, the Indian Gaming Regulatory Act (IGRA), and any Class III gaming rules.

4.02.  	Sovereign Immunity of the Gaming Commission.  The Gaming Commission is clothed by Federal and Tribal law with all the privileges and immunities of the Tribe including sovereign immunity from suit in any state, federal or Tribal court, except as may be specifically provided for in the Gaming Ordinance #10-400-01, for the purposes of hearings and appeals of licensing determinations and the issuance of fines.

a.  	Nothing in this Ordinance shall be deemed or construed to be a waiver of sovereign immunity of the Gaming Commission from suit.

b.  	Nothing in this Ordinance shall be deemed or construed to be a consent of the Gaming Commission to the jurisdiction of the United States or any state or of any other tribe with regard to the business or affairs of the Gaming Commission.

4.03. 	Waiver of Sovereign Immunity of the Gaming Commission.  The sovereign immunity of the Gaming Commission may be waived only by express resolution of the Tribal Council.  Neither the power to sue and be sued provided below in Section 6.01(k), nor the consent to jurisdiction and waiver of sovereign immunity regarding licensing determinations or the issuance of fines, nor any express waiver of sovereign immunity by resolution of the Tribal Council shall be deemed a consent to levy of any judgment, lien or attachment upon property of the Tribe, whether or not under the control and management of the Gaming Commission.

4.04.  	Sovereign Immunity of the Tribe.  All inherent sovereign rights of the Tribe as a federally-recognized Indian Tribe with respect to the existence and activities of the Gaming Commission are hereby expressly reserved, including sovereign immunity from suit in any state, federal or Tribal court.  Nothing in this Ordinance, nor any action of the Gaming Commission, shall be deemed or construed to be a waiver of sovereign immunity from suit of the Tribe; or to be a consent of the Tribe to the jurisdiction of the United States or of any state or any other Tribe with regard to the business or affairs of the Gaming Commission or the Tribe; or to be a consent of the Tribe to any cause of action, case or controversy, or to the levy of any judgment, lien or attachment upon any property of the Tribe; or to be a consent to suit with respect to any lands in the Tribe's Reservation, or to be a consent to the alienation, attachment or encumbrance of any such land.

4.05. 	Assets of the Gaming Commission.  The Gaming Commission shall have only those assets specifically assigned to it by the Tribal Council or acquired in its name by the Tribe.  No activity of the Gaming Commission nor any indebtedness incurred by it shall implicate or in any way involve assets of the Tribe not assigned in writing to the Gaming Commission.

Article V.  Appointment of Gaming Commissioners; Qualifications

5.01.  	Number of Gaming Commissioners.  The Gaming Commission shall be composed of not less than three (3), but no more than five (5) Commissioners. 

5.02. 	Quorum; Reduced Number of Gaming Commissioners.  If there are fewer than five (5) members of the Gaming Commission, a majority of the remaining duly appointed Commissioners shall constitute a quorum.  If the number of Gaming Commissioners on the Gaming Commission is reduced to less than three (3), quorum shall consist of all the Gaming Commissioners remaining on the Gaming Commission.  All quorums must require at least one Officer to be present.
	A Tribal Council liaison for the Gaming Commission may temporarily serve as a voting Commissioner if the Commission By-Laws require another member to achieve a quorum.  The Tribal Council liaison will have full authority of a Commissioner from the time a Commission meeting is called to order until the same meeting has been adjourned.  The liaison serving as a temporary Commissioner must have passed the same background check requirements that a seated Commission on the Commission must pass in order to serve as a temporary Commissioner.

5.03. 	Appointment of Gaming Commissioners.  

a.  	The members of the Gaming Commission shall be appointed by the Ogema and approved by the Tribal Council.  Members may be reappointed for additional terms without limitation.  The term of office is four (4) years.

b.  	Future Appointments. At least four (4) weeks prior to any meeting during which appointments to the Gaming Commission will be made, the Ogema shall publicize that he/she will be making such nominations for appointments and is seeking applications from individuals to be considered for appointment.

5.04.  	Qualifications of Commissioners. 

a.	Any enrolled member of the Tribe, at least eighteen (18) years of age who is not an elected, appointed government official or an employee reporting directly to the Office of Ogema, the Tribal Court, or Tribal Council.  

b.	Each newly appointed Commissioner must attend training on the Indian Gaming Regulatory Act, regulations promulgated by the National Indian Gaming Commission, federal revenue laws relating to gaming, the Gaming Ordinance #10-400-01, any regulations adopted by the Gaming Commission, and gaming operations and structures.

5.05.	Background Investigation.  Before any applicant may be appointed to serve on the Gaming Commission, the Ogema shall arrange to have performed a comprehensive background check of the applicant to be conducted by the Gaming Commission.  The applicant shall be required to meet the eligibility standards applied to Gaming (Key) Employees as defined in Section 10.02 of Gaming Ordinance #10-400-01 and as outlined below.  An Investigative Report detailing the results of the completed background investigation shall be submitted to the Tribal Ogema and then to the Tribal Council (in a closed session meeting) for review prior to approving or denying the appointment recommended by the Ogema.  No person shall serve as a Commissioner if:

a.  	Activities.  That person’s prior activities within the past fifteen (15) years, including criminal records, reputation, habits or associations:

1.  	Pose a threat to the public interest; or

2.  	Threaten the effective regulation and control of gaming; or

3.  	Enhance the dangers of unsuitable, unfair, or illegal practices, methods, or activities in the conduct of gaming; or

b.  	Criminal Convictions and Pleas.

1.  	Felony.  That person has been convicted of, or entered a plea of guilty or no contest to a gaming-related offense, fraud or misrepresentation at any time; or

2.  	That person has been convicted of or entered a plea of guilty or no contest to any offense not specified in paragraph (b) (1) within the immediately preceding five (5) years; this provision shall not apply if that person has been pardoned by the Governor of the State where the conviction occurred or, if a Tribal Member, has been determined by the regulatory agency to be a person who is not likely again to engage in any offensive or criminal course of conduct and the public good does not require that the applicant be denied a Gaming Employee License. The term “any offense” shall mean any criminal offense not described in paragraph (3), whether committed in Michigan or any other jurisdiction, that is, or would be, a crime under the provisions of the Michigan Penal Code, Act 328 of the Public Acts of 1931, as amended being MCL 750.1 to 750.568, or the controlled substances provisions of the Public Health Code, Act # 68 of the Public Acts of 1978, as amended, being MCL 333.7101 to 333.7545, or any other criminal offense not included within the scope of paragraph (3) involving theft, dishonesty, fraud or misrepresentation arising under the law of Michigan or another state or jurisdiction, that was committed as an adult or prosecuted as an adult offense, and which has not been effectively removed from the employee’s criminal record by executive pardon, state court order, or operation of law; or

3.  	Has knowingly and willfully provided materially false and misleading statements or information to the Gaming Commission or has refused to respond to questions and/or requests for information asked by the Gaming Commission specifically related to the person’s eligibility to obtain or retain a license; or

4.  		Has been convicted of any offense related to sexual crimes or criminal sexual conduct where the perpetrator was convicted as an adult at the time the crime was committed, and/or is registered in any jurisdiction’s list of sexual offenders; or 

5.  	Misdemeanor.  Has been convicted or entered a plea of nolo contendere to a misdemeanor involving dishonesty or moral turpitude within the past five (5) years; or

c.  	That person has a present financial interest in the conduct of any gaming enterprise in which the person has the ability to change or affect the conduct of any gaming enterprise; or

d. 	That person is an employee of the Gaming Commission; or

e.  	That person has a member of his immediate family and residing in the same household, who is employed as a Key Employee or Primary Management Official by any gaming enterprise; or

f.  	Fails to disclose a conflict of interest, as defined in Section 5.06. 

In the event a disqualifying event, as defined in paragraph (c), (d), or (e) of this Section, occurs after the date a person’s appointment to the Gaming Commission has been confirmed by the Tribal Council, that Commissioner may continue to serve on the Commission for up to 120 days after the date the disqualifying event occurred so that the Ogema may begin the process of submitting a new candidate for appointment to the Gaming Commission.  In the event of any other disqualifying event, as defined in this Section, the Tribal Council may take immediate steps to remove that Commissioner.

5.06. 	Conflict of Interest.  Prior to their appointment, persons nominated to the Gaming Commission shall disclose the names and addresses of immediate family members, if such immediate family members are employed at any gaming enterprise or if such family members are employed by the Gaming Commission, or if they or a member of their immediate family has a financial interest in any gaming service business.  Gaming Commissioners are prohibited from participating in making decisions, which involve balancing personal financial interests or the interests of members of that Commissioner’s immediate family, other than interests held in common by all Tribal members, against the interests of the Gaming Commission or the Tribe.  Failure to disclose a conflict of interest, or to refrain from participating in decisions that involve a conflict of interest, shall be grounds for removal of a Commissioner pursuant to Section 5.07.

5.07.  	Removal of Members or Vacancies.

a.  	Removal; Causes For. A Commissioner may be removed for the following reasons, and as may be set forth in the Commissions Ordinance, #04-150-01: 

1.  	Serious inefficiency; 

2.  	Neglect of duty, malfeasance, misfeasance, nonfeasance, misconduct in office; or 

3.  	For any conduct which threatens the honesty and integrity of the Gaming Commission or otherwise violates the letter or intent of this Ordinance.

b.  	Removal; Process. A Commissioner may be removed as set forth in the Removal Rules and Procedures Ordinance, #01-150-02, or by a resolution in favor of removal supported by seven (7) members of the Tribal Council for the reasons set forth in Section 5.07 (a).

c.  	Vacancies.  If any Commissioner shall die, resign, be removed or for any reason be unable to serve as a Commissioner, the Gaming Commission shall notify the Ogema who shall declare the position vacant and shall appoint another person to fill the position in accordance with the Commissions Ordinance.

Article VI. Powers and Responsibilities of Gaming Commission

6.01.  	Powers of the Gaming Commission. In furtherance, but not in limitation, of the Gaming Commission’s purposes and responsibilities, and subject to any restrictions contained in this Ordinance or other applicable law, the Gaming Commission shall have and is authorized to exercise by majority vote, the following powers:

a.  	To regulate all day-to-day gaming activity within the jurisdiction of the Tribe to ensure the integrity thereof, which includes, but is not limited to the adoption, review and approval of internal controls, procedures, processes, and other documents which relate to the operation of the gaming enterprise and businesses conducted under the gaming enterprise.

b.  	To promote the full and proper enforcement of all tribal civil and criminal gaming laws.

c.  	To issue, deny, suspend or revoke any license necessary to operate, manage, conduct business with or be employed at any gaming enterprise authorized by this Ordinance or any other Tribal laws, and to establish a schedule of fees as may be necessary to defray expenses of license processing and background investigations.

d.  	To conduct or cause to be conducted, background investigations of persons or business entities applying for any license.

e.  	To enact and enforce such regulations consistent with this Ordinance regarding its activities as the Gaming Commission may deem necessary and proper to effectuate the powers granted by this Ordinance and duties imposed by applicable law.  Such enforcement may include levying fines and fees.

f.  	To arrange for and direct such inspections and investigations as it deems necessary to ensure compliance with this Ordinance, the Gaming Ordinance #10-400-01, any federal law, or other applicable laws and regulations. In undertaking such investigations, the Gaming Commission may request the assistance of federal, state and Tribal law enforcement officials, legal counsel and other third parties.

g.  	To administer oaths, conduct hearings, and by subpoena compel any licensee or license applicant, any person employed by a gaming enterprise, and any person doing business with a gaming enterprise to appear before it and to provide such information, documents or other materials as may be in their possession to assist in any investigation conducted by the Gaming Commission relating to the enforcement of gaming laws and regulations.

h.  	To make, or cause to be made by its agents or employees, an examination or investigation of the place of business, equipment, facilities, tangible personal property, and the books, records, papers, vouchers, accounts, documents and financial statements of any gaming enterprise operating, or suspected to be operating, within the jurisdiction of the Tribe.

i.  	When necessary or appropriate, to request the assistance and utilize the services of the courts, law enforcement and government officials and agencies, and private parties, in exercising its powers and carrying out its responsibilities.

j.  	To close, after notice and a hearing, any game or games which are operating in violation of Tribal or federal law.

k.  	To sue or be sued in courts of competent jurisdiction within the United States subject to the provisions of this ordinance and other laws relating to sovereign immunity; provided, that no suit shall be brought by the Gaming Commission without the prior explicit written approval of the Tribal Council.

l.  	Where it is in the best interest of the Tribe, to develop a cooperative working relationship with federal, state and other Indian Tribes, agencies and officials.

m.  	To investigate any aspect of any gaming enterprise in order to protect the public interest in the integrity of gaming and to prevent improper and unlawful conduct. The Gaming Commission shall investigate any report of a failure of any gaming enterprise to comply with this Ordinance, the Gaming Ordinance, or any Tribal laws, or any other regulations adopted by the Gaming Commission, IGRA, or the Tribal-State Compact. The Gaming Commission may issue an Order requiring any gaming enterprise to take any corrective or remedial action deemed necessary.

n.  	To arbitrate, compromise, negotiate or settle any dispute to which it is a party relating to the Gaming Commission’s authorized activities.

o. 	To make application and accept grants and other awards from private and governmental sources in carrying out or furthering the purposes of the Gaming Commission.

p.  	To exercise all authority delegated to it or conferred upon it by law and to take all action which shall be reasonably necessary and proper for carrying into execution the foregoing powers and all of the powers vested in this Ordinance as permitted by the purposes and powers herein stated, which are deemed to be in the best interests of the Tribe and in compliance with applicable law.

q.  	Pursuant to the Tribal law, to initiate a suspension or revocation proceeding of a liquor license issued to a gaming enterprise.

r.   	Record-keeping requirements, the Gaming Commission shall approve the accounting system and record keeping controls of each gaming enterprise conducting Class III gaming

6.02.  	Additional Powers and Duties.

a.  	The Gaming Commission shall require the General Manager of each gaming facility licensed by the Tribe to prepare a plan for the protection of public safety and the physical security of patrons of gaming facilities, setting forth the respective responsibilities of the Gaming Commission, the Security Department of the gaming facility(ies), and any applicable or appropriate police agency(ies).  Such plan, and any subsequent modifications thereof, shall be submitted to the Gaming Commission annually for its review and approval.

b.  	The Gaming Commission shall enforce all Tribal health and safety standards applicable to gaming facilities licensed by the Tribe.

c.  	The Gaming Commission shall establish a list of persons barred from gaming facilities because of their criminal history or association with career offenders or career offender organizations which pose a threat to the integrity of gaming.

d.  	The Gaming Commission shall publish and distribute copies of this Ordinance, Gaming Commission regulations, and any Tribal Council, Gaming Commission or Tribal Court decisions regarding gaming matters.

e.  	The Gaming Commission shall maintain and keep current a record of new developments in the area of Indian gaming.

f.  	The Gaming Commission shall obtain and publish a summary of federal revenue laws relating to gaming and to ensure compliance with the same.

g.  	The Gaming Commission shall arrange for training of Gaming Commissioners, Gaming Commission employees and others in areas relating to the regulation of gaming.

h.  	The Gaming Commission shall consult with and make recommendations to the Tribal Council regarding changes in gaming laws.

6.03.	Annual Budget. The Gaming Commission shall prepare an annual operating budget for all Gaming Commission activities and present it to the Ogema and the Tribal Council in accordance with Budget and Appropriations Act of 2013 – Ordinance #13-100-04 established by the Constitution and Ordinances adopted by the Tribal Council.

a.  	Expenditures.  Any and all expenditures from the Gaming Commission budget shall be in conformance with the policies of the Tribe in regards to the expenditure of Tribal funds.  Provided further, that whenever Tribal Council approval is necessary to make an expenditure or to enter into an agreement, that approval shall be approved by the Tribal Council by resolution and approvals for expenditure of funds shall not be unreasonably withheld.

b.  	Budget Not to be Amended.  The annual budget approved by the Ogema and the Tribal Council for the Gaming Commission shall not be amended to reduce the budget.  Provided that, the Ogema and the Tribal Council may make amendments to supplement the budget of the Gaming Commission in accordance with approved processes.

6.04.  	Gaming Commission Regulations.

a.  	Gaming Commission shall promulgate regulations consistent with this Ordinance and necessary to carry out the orderly performance of its duties and powers which shall include, but shall not be limited to the following:

1.  	Internal operational policies and procedures of the Gaming Commission and its staff;

2. 	Interpretation and application of gaming related laws and regulations as may be necessary to carry out the Gaming Commission's duties and exercise its powers;

3.  	A regulatory system for all gaming, including accounting, contracting, and surveillance, to ensure the integrity, honesty and fairness of all gaming;

4.  	The conduct of inspections, investigations, hearings, enforcement actions and other powers of the Gaming Commission.

b.  	No regulation of the Gaming Commission shall be of any force or effect unless it is adopted by the Gaming Commission by written resolution and filed with the Tribal Council Recorder, which shall then be placed on the Tribal Council agenda for acceptance.

c.  	The Tribal Court and any other court of competent jurisdiction shall take judicial notice of all Gaming Commission regulations adopted pursuant to and consistent with this Ordinance and other requirements for the adoption of regulations as may be set in place by the Tribal Council.

6.05.  	Right of Entrance. The Gaming Commission and authorized personnel of the Gaming Commission may enter upon any premises of any gaming enterprise for the purpose of making inspections and examining the accounts, books, papers, and documents, of any such gaming enterprise during any operating period of the gaming enterprise. The General Manager of each gaming enterprise shall facilitate such inspection or examinations by giving every reasonable aid to the Gaming Commission and to any authorized personnel of the Gaming Commission

6.06.  	Investigations. The Gaming Commission and authorized personnel may investigate and examine the operation and premises of any gaming enterprise subject to the provisions of the Tribal-State Compact, IGRA, this Ordinance, the Gaming Ordinance, or regulations of the Gaming Commission. In conducting such investigations, the Gaming Commission may proceed either with or without a hearing as it may deem best, but it shall make no order without first affording any affected party notice and an opportunity for a hearing pursuant to Gaming Commission regulations.

6.07.  	Hearings; Examiner. The Gaming Commission may hold any hearing it deems to be reasonably required in the administration of its powers and duties.  The Gaming Commission may designate one (1) of its members to act as examiner for the purpose of holding any such hearing or the Gaming Commission may appoint another person to act as examiner under Section 6.08.  The Gaming Commission hearing regulations shall, at a minimum, afford any affected party, and all people interested therein as determined by the Gaming Commission, the right to appear personally before the Gaming Commission, the right to be represented by counsel at the affected party's own expense, the right to face and question witnesses against the affected party, and the right to present relevant oral or documentary evidence.

6.08.  	Appointment of Examiner. The Gaming Commission may appoint any person qualified in the law or possessing expertise in the subject matter of the hearing to act as examiner for the purpose of holding any hearing that the Gaming Commission has the authority to hold. Examiners appointed under this Section shall not have the power to make findings or issue orders.

6.09.  	Gaming Commission Employees.  Subject to the approval of an appropriation of funds, the Gaming Commission may employ such personnel as may be required to fulfill the Gaming Commission’s responsibilities under this Ordinance.  The Gaming Commission shall be required to develop policies for employment standards.

6.10.  	Gaming Commission Department Organization.  The Gaming Commission shall be required to submit to the Tribal Council, for acceptance, the Organizational Chart of the Gaming Commission Department on an annual basis.  At a minimum, the organization of employees of the Gaming Commission shall include departments and/or the responsibilities of Surveillance, Compliance, Internal Audit, and Licensing.

6.11.  	Personnel Procedures.  The Executive Director over the Gaming Commission Department shall hire and manage employees in accordance with the Tribe’s personnel ordinances or regulations.  The Gaming Commission shall be responsible for employment related decisions as the final appeal body, or the final decision maker under the Tribe’s personnel laws or regulations.

Article VII. Audit Required; Report to National Indian Gaming Commission

7.01.  	Annual Audit. In accordance with the Gaming Ordinance, the Gaming Commission shall conduct or have conducted an independent audit of all gaming enterprises on an annual basis and shall submit the resulting audit reports to the Tribal Council and the National Indian Gaming Commission.

7.02.  	Audit to Include Contracts for Gaming Services, Equipment, Concessions, or Supplies. All contracts for gaming services, gaming equipment, concessions or supplies shall be specifically included within the scope of the audit if inclusion is deemed necessary to protect the public interest in the integrity of the operation of the gaming enterprise.

Article VIII.  Licensing

8.01.  	Licensing Regulations.  In accordance with the Gaming Ordinance, the Gaming Commission shall promulgate rules and provide notice for all licensing requirements.

8.02.  	Hearing Processes.  As identified in this Ordinance, and in accordance with the Gaming Ordinance, the Gaming Commission shall promulgate procedures for holding hearings.  Provided that, the rules of evidence as adopted by the Tribal Court shall apply to hearings held by the Gaming Commission.

CERTIFICATION

I, Gary DiPiazza, Tribal Council Recorder, do hereby certify that this is a true and correct copy of the Gaming Commission Ordinance permanently adopted by the Tribal Council on May 8, 2002 and amended most recently by Tribal Council on ____________, 2020. 

                                                                        				[Seal]