MATTHEW PAPPAS (CA. SBN #: 171860) 

Pro hac vice application pending 

Oklevueha Native American Church 

17 19 E. Broadway 

Long Beach, CA 90802 

Phone: (949) 382-1485 

Facsimile: (949) 242-2605 

E-Mai I: matt.pappas@mattpappaslaw .com 

MICHAEL ROSE (OSB #: 753221) 

Creighton & Rose P .C. 

815 SW 2nd Ave., Ste. 500 

Portland, OR 97204 

Phone: (503) 22 1-1792 

Facsimile: (503) 223-1516 

E-Mai I: mrose@civilrightspdx.com 

Attorneys for Plaintiffs 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

PORTLAND DIVISION 

OKLEVUEHA NATIVE AMERICAN 

CHURCH; JAMES MOONEY; and JOY 

GRAVES, 

Plaintiffs, 

v . 

UNITED STATES OF AMERICA; 

UNITED STATES POSTAL SERVICE; 

and MEGAN J. BRENNAN, in her capacity 

as Postmaster General of the United States, 

Defendants. 

VERIFIED COMPLAINT FOR 

VIOLATION OF THE RELIGIOUS 

FREEDOM RESTORATION ACT; 

THE RELIGIOUS LAND USE AND 

INSTITUTIONALIZED PERSONS 

ACT; AND INJUNCTIVE RELIEF 

(AMENDED) 

Plaintiffs OKLEVUEHA NATIVE AMERICAN CHURCH, JAMES MOONEY and 

JOY GRAVES complain of violations of the Religious Freedom Restoration Act and Religious 

Land Use and Institutionalized Persons Act as fo llows: 

AMENDED COMPLAINT- I 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 1 of 28
JURISDICTION AND VENUE 

1. Plaintiffs seek relief for violations of 42 U.S.C. 2000bb, et seq. and 42 U.S.C. 

2000cc, et seq. providing this court with subject matter jurisdiction pursuant to 28 U.S.C. §§ 

1331 and 1338. 

2. Venue is proper in this Judicial District because the injury alleged in this 

Complaint occurred in Portland, Oregon. 

PARTIES 

3. PlaintiffOKLEVUEHA NATIVE AMERICAN CHURCH ("CHURCH") is a 

Native American Church based in the State of Utah. A branch of CHURCH operates in Cottage 

Grove, Oregon. Plaintiff JAMES MOONEY ("MOONEY") is a co-founder of CHURCH and 

serves as its spiritual leader. 

4. Defendant UNITED STATES OF AMERICA ("'UNITED STATES") is a 

sovereign with limited powers operating pursuant to the Constitution of the United States. 

Defendant UNITED STATES POSTAL SERVICE ('·POSTAL SERVICE") is an agency of 

Defendant UNITED STATES . Defendant MEGAN J. BRENNAN ("BRENNAN") is sued 

solely in her capacity as Postmaster General ofDefendant POSTAL SERVICE. 

5. Plaintiff JOY GRAVES ("GRAVES") is an individual and member of CHURCH 

who resides in Cottage Grove, Oregon. GRAVES is a leader of CHURCH's branch located in 

Cottage Grove, Oregon. ORA VES is a citizen of Defendant UNITED STATES. 

JURISDICTIONAL PREREQUISITES 

6. No goverrunent claim filing prerequisite is applicable in this case which seeks only 

injunctive and declaratory relief remedies. 

7. The actions complained of by Plaintiffs began taking place on or around 

December 10. 2015 and all such actions took place in the District of Oregon. 

STATUTORY AND DECISIONAL LAW ALLEGATIONS 

8. Under the Religious Land Use and Institutionalized Persons Act (RLUIPA), 42 

U.S.C. §§ 2000cc, et seq., "No government shall impose or implement a land use regulation in a 

AMENDED COMPLA i r\'T- 2 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 2 of 28
manner that imposes a substantial burden on the religious exercise of a person, including a 

religious assembly or institution, unless the government demonstrated that imposition of the 

burden on that person, assembly, or institution, (A) is in furtherance of a governmental interest; 

and (B) is the least restrictive means of furth ering that compelling governmental interest. 

CHURCH is a religious assembly or institution for purposes of the RLUIP A. Plaintiffs 

MOONEY and GRA YES are both pers~ms" for purposes ofRLUIPA. 

9. The American Indian Religious Freedom Act, 42 U.S.C. § 1996 ("AIRFA") 

protects and preserves the traditional religious rights and cultural practices of American Indians, 

Eskimos, Aleuts, and Native Hawaiians. These rights include, but are not limited to, access to 

sacred sites, freedom to worship through ceremonial and traditional rights, and use and 

possession of objects considered sacred. AIRF A was amended in 1994 to specifically protect 

the sacramental use of peyote by Native Americans. CHURCH is an "Indian re ligion" as 

defined by AIRF A. 

10. The Religious Freedom Restoration Act of 1993 (RFRA), 107 Stat. 1488, as 

amended, 42 U.S.C. § 2000bb et seq., applies to the Federal government, including each of the 

Defendants, and prohibits law and rules of the United States from substantially burdening a 

person's exercise of religion even if the burden results from a rule of general applicability. The 

RFRA requires the "strict scrutiny" review standard be used when analyzing federal laws and 

rules that burden free exercise. The RFRA applies ··to all Federal law, and the implementation 

of that law, whether statutory or otherwise." 

11. In Gonzales v. 0 Centro Espirita Beneflciente Uniao do Vegetal, 546 U.S. 418 

(2006) the U.S. Supreme Court held the federal Controlled Substances Act (CSA), 21 U.S.C. § 

801 et seq. does not meet the as applied "strict scrutiny'' standard expressed in the RFRA. 

12. Between March 1, 2014 and December 14,2014. the United States House of 

Representatives and United States Senate voted to enact H.R. 83, an appropriations bill. Prior to 

its enactment, I-l.R. 83 was amended to include Section 538 (Sec. 538) which prohibited the 

Department of Justice from using funds in a manner inapposite to the implementation of state 

medical marijuana laws in 32 states and the District of Columbia. Thereafter, on December 16, 

AMENDED COMPLAINT - 3 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 3 of 28
2014, the President signed H.R. 83, which was codified as Public Law 113-265 and provides in 

Sec. 538: 

"None of the funds made available in this Act to the Department of Justice may 

be used, with respect to the States of Alabama, Alaska, Arizona, California, 

Colorado, Connecticut, Delaware, District of Columbia, Florida, Hawaii, 

Illinois, Iowa, Kentucky, Maine, Maryland, Massachusetts, Michigan, 

Minnesota, Mississippi, Missouri, Montana, Nevada, New Hampshire, New 

Jersey, New Mexico, Oregon, Rhode Island, South Carolina, Tennessee, Utah, 

Vermont, Washington, and Wisconsin, to prevent such States from 

implementing their own State laws that authorize the use, distribution, 

possession, or cultivation of medical marijuana." 

13. In 20 15, Congress voted to reauthorize Sec. 538 for fiscal2016. 

14. The State of Oregon has enacted Jaws providing for medical marijuana, the 

Oregon Medical Marijuana Act, codified as Or. Rev. Stat. § 4 75.300 (2007); Or. Rev. Stat. §§ 

475.302(5); 475.3 12(2) (2007). 

15. As of the filing of this Complaint, more than thirty-two (32) states and the District 

of Columbia have enacted some form of cannabis legislation for patients suffering from severe 

illness and disability; (B) Congress enacted Sec. 538 restricting the use of funds by the federal 

Department of Justice against implementation of medical cannabis laws in 32 states; (C) in 

January, 2013, the National Cancer Institute, part of the federal government's National Institutes 

of Health, reported cannabis reduces the size of cancerous tumors; (D) in 2003, the United 

States obtained a patent titled, "The Antioxidant and Neuroprotective benefits of Cannabinoids;" 

(E) multiple scientific studies and reports show cannabis is the only medication effective in 

treating severe childhood epilepsy: and (F) numerous scientific articles report cannabis is 

effective in treating a myriad of human health ailments. 

16. As a result of: (A) Congress's enactment of Sec. 538; (B) the enactment of 

Oregon's medical marijuana laws; (C) the publication of numerous studies showing cannabis is 

safer than alcohol; (D) the use of sacramental wine by other religious groups; (E) numerous 

actions taken by the Article II Branch restricting the use of resources for purposes of federal 

marijuana prosecutions; (F) the many respected medical studies showing the health benefits 

AMENDED COM PLAINT - 4 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 4 of 28
provided by cannabis; and (G) the hundreds of years of traditional use of cannabis and the 

federally allowed use of peyote and other natural plants by Native Americans in their religious 

practices, there is no longer even a rational basis justify ing confiscation of marijuana by the 

Defendants that is used by CHURCH for its religious practices and ceremonies. 

17. Through substantive due process "emerging awareness", the members of 

CHURCH who use cannabis as part of Native American spiritual healing practices that integrate 

into CHURCH's religious beliefs the concept of medicine-men, healing and being one with the 

Earth have a fundamental right to do so to alleviate and treat physical and mental conditions 

from which they suffer. Lawrence v. Texas, 539 U.S. 558, 578, 123 S.Ct. 2472, 156 L.Ed.2d 

508 (2003); Raich v. Gonzales, 500 F.3d 850, 864-66 (2007). 

COMMON FACTUAL ALLEGATIONS 

18. CHURCH was established in April of 1997 in Gunnison, Utah by Plaintiff James 

Mooney, the progeny of Native Americans, and by his wife Linda, also of Native American 

descent (together referred to as "MOONEYS"). Plaintiff MOONEY is a descendant of Osceola 

(1804-1 838), an influentiallcader of the Seminole Indian Tribe in Florida. (See Exhibit 1, 

Oceola, Cherokee and Creek Indian Reservation Tribal Card.) Plaintiff MOONEY continues to 

serve as the spiritual leader of CHURCH, which in 2007 was recognized and serves the federally 

recognized Oglala Sioux Tribe of Pine Ridge as the Oklevueha Lakota Sioux Nation Native 

American Church. (See Exhibit 2, Articles of Formation, incorporated by this reference.) 

CHURCH is also recognized by the Lakota Sioux Rosebud Tribe of South Dakota. 

19. CHURCH has thousands of members in the Un ited States, Canada, Mexico, South 

America and Africa. 

20. Part of Plaintiff CHURCH's religious practices includes Native American 

"medicine men." The integration into its religion of nature, natural health and the "medicine 

men" is a core principal and part of the CHURCH's ongoing Native American practices that 

have been part ofNative American culture and religious practice for hundreds of years. Along 

with peyote, cannabis and various other natural herbs and plants are used in the sacramental 

processes by CHURCH medicine men and members. 

AMENDED COM PLAI NT- 5 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 5 of 28
21. In 2000, CHURCH became affiliated with the Huichol tribe, an indigenous people 

of Sonora, Mexico. The proclamation between CHURCH and the Huichol tribe is included as 

Exhibit 3 with this Complaint and incorporated by this reference. 

22. The Huichol are a deeply religious people that have a belief structure which 

encompasses every aspect of life and includes ceremonies from pre-Colombian mythology that 

places special emphasis on the deer, corn plant, and the peyote plant, a small, spineless, 

flowering cactus plant which is used as a hallucinogen before and during religious ceremonies. 

For hundreds of years, the Huichol have used a common form of hemp called mariguana or rosa 

maria (Cannabis sativa) in their spiritual healing practices. 

23. Since its inception, CHURCH has followed traditional Native American religious 

ceremonies including those of the indigenous people and tribes with which it is affiliated. 

Cannabis is integral to CHURCH's spiritual healing practices. 

24. Since 1997, numbers of branches of CHURCH have been established around the 

United States, including its branch located at 1630 Curtin Road, Cottage Grove, Oregon 

("BRANCH"). Each CHURCH branch is blessed by James Mooney and conducts the Native 

American religious ceremonies, rituals and spiritual healing practices of CHURCH using 

peyote, cannabis and other plants. 

25. In or around 1999, the State ofUtah wrongfully arrested the MOONEYS and 

charged them as well as CHURCH with violating the Utah Controlled Substances Act 

("UCSA"). 

26. In 2004, the Utah Supreme Court held the religious peyote provisions of 42 U.S.C. 

§ 1996a protected the MOONEYS and CHURCH from prosecution for the religious use of 

peyote under the UCSA. As a result of the state's highest court's decision, charges against 

CHURCH and the MOONEYS were dismissed. State of Utah v. Mooney, 2004 UT 49 (2004). 

27. GRJ\ YES serves as the leader of CHURCH's BRANCH in Cottage Grove 

Oregon. GRA YES has been blessed by James Mooney as has the BRANCH in Cottage Grove, 

Oregon. GRA YES prepares the sacraments used by CHURCH members pursuant to their 

religious beliefs including but not limited to cannabis. Sacramental cannabis grown by 

AMENDED COMPLA I NT - 6 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 6 of 28
BRANCH is used by members ofBRANCH as well as other branches of CHURCH. GRA YES 

distributes sacraments to CHURCH members who are a part of BRANCH. 

28. On or around December 10, 201 5, GRAVES prepared a package including 

sacramental cannabis for a CHURCH member located in Ohio. The package contained 

approximately five (5) ounces of cannabis. 

29. The package included on it that it was from CHURCH. 

30. The package was addressed to the member in Ohio with "ONAC" (the acronym 

used by CHU RCH) in the address line. 

31. On December 10, 20 15, GRAVES submitted the package for mailing to the United 

States Post Offi ce in Eugene, Oregon. The package was sent "Priority Mail" and was assigned 

USPS tracking number 9505 5141 7801 5344 1322 75. 

32. On or around December 18, 201 5, GRA YES learned from the United States Postal 

Service web tracking page that the package had been seized by Defendant UNITED STATES at 

its post office in Portland, Oregon for " law enforcement" reasons. (See Exhibit 4, USPS. com 

Tracking report.) 

33. The ·'status" of the package as reported by USPS.com (as reported in Exhibit 4) is 

"Seized by Law Enforcement." 

34. On December 22, 20 15, GRAVES contacted the United States Post Office in 

Portland, Oregon and was directed to Postal Inspector Melvin. GRA YES spoke to Inspector 

Melvin who told her the package had been seized by the Postal Service because it contained 

cannabis. GRA YES told Inspector Melvin she was a member and branch leader of CHURCH 

and the cannabis was for sacramental purposes fo r members in Ohio. She asked the package be 

sent through to Ohio and Inspector Melvin refused to release the package. Inspector Melvin told 

GRA YES that cannabis is illegal under the federal Controlled Substances Act and would not be 

returned, released or delivered to the church member in Ohio. GRA YES again explained the 

cannabis was used in CHURCH's spiritual healing practices. 

35. The cannabis sent by GRA YES was sent to a member of CHURCH for 

sacramental purposes and as part of the religious practices of Cl-JURCH. 

AMENDED COMPLAINT- 7 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 7 of 28
36. The sacramental cannabis included in the package was in-part sent for healing 

purposes as part of CHURCH's healing sacraments for a woman suffering from esophageal 

cancer. Each day the sacrament is delayed, the healing process provided through the CHURCH 

is denied to its member suffering from esophageal cancer as well as is denied for other of 

CHURCH's spiritual healing practices. 

37. As of the date ofthe filing ofthis Complaint, the sacramental cannabis remains in 

the custody of the Defendants who continue to refuse to release it. 

FIRST CLAIM FOR RELIEF 

(Religious Freedom Restoration Act (RFRA), 

42 U.S.C. §§ 2000bb, et seq.- Against All Defendants) 

38. Plaintiffs re-allege and incorporate the allegations included in paragraphs 1-37 of 

this Complaint. 

39. As part of the Federal government, RFRA applies to Defendants POSTAL 

SERVICE, UNITED STATES and BRENNAN. Gonzales v. 0 Centro Espirita Beneficente 

Uniao do Vegetal, 546 U.S. 418 (2006) [O 'Centro]; Burwell v. Hobby Lobby, 573 U.S. _ 

(20 14). 

40. The Defendants have seized sacramental cannabis of Plaintiff CHURCH and have 

refused to release, return or deliver as addressed the cannabis, which is used by church in its 

sacramental healing practices and religious rituals. 

41. Plaintiffs are informed and believe and based upon such information and belief 

allege the seizure ofthe sacramental cannabis of CHURCH was done based on provisions of21 

U.S.C. § 801 , et. seq, the federal Controlled Substances Act ("CSA"). Inspector Melvin, as set 

forth above, told Plaintiff GRA YES on December 21, 201 5 that cannabis was illegal under the 

CS!\. when he refused to return, release or deliver to the addressed recipient the cannabis used 

by CHURCH in its spiritual healing practices and religious rituals. 

42. The RFRA is applicable to the laws and rules of the Defendants, each part of the 

Federal government, when the rules or laws at issue - even applicable generally and not targeted 

at religion - substantially burden the free exercise of religion. 

AMENDED COMPLA I 'T- 8 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 8 of 28
43 . In 0 'Centro, supra, the United States Supreme Court deemed the UNITED 

STATES had failed to show a compelling government interest for purposes ofRFRA in a case 

involving a CSA Schedule I controlled substance. 

44. The seizure of the sacramental cannabis by the Defendants has placed a substantial 

burden on the spiritual healing practices of CHURCH, ORA YES, MOONEY and CHURCH 's 

members because without it, the spiritual healing practices and rituals cannot be performed. 

43. The Defendants do not have a compelling government interest justifying seizure of 

CHURCH's sacramental cannabis because the purpose of the CSA as announced by Congress in 

the 1971 Comprehensive Drug Abuse Prevention and Control Act was to combat the 

recreational abuse of drugs. 

44. Cannabis used in CHURCH's spiritual healing practices, rituals, ceremonies, and 

as a sacrament is not the recreational abuse of drugs and the CSA's broad restriction of cannabis 

that substantially burdens the Plaintiffs' religious rights is not the least restrictive means of 

combatting recreational drug abuse. 

45. The actions of the Defendants violate the RFRA and the Plaintiffs seek injunctive 

relief as set forth below. 

SECOND CLAIM FOR RELIEF 

(Religious Land Use and Institutionalized Persons Act (RLUIPA), 

42 U.S.C. §§ 2000cc, et seq.- Against All Defendants) 

46. Plaintiffs re-allege and incorporate the allegations included in paragraphs 1-37 of 

this Complaint. 

4 7. BRANCH is located on land in Oregon that does not infringe on or interfere with 

any other property near or around it. The land used by BRANCH is located in a state that has 

enacted laws allowing the cultivation of cannabis and in a state listed in Section 538 where 

Congress has prohibited use of funds by the federa l Department of Justice related to 

implementation of medical cannabis laws, including cultivating cannabis on the land. As part of 

CHURCH, BRANCH cultivates cannabis for spiritual healing practices, as a sacrament and for 

use in Native American rituals. BRANCH's cultivation responsibilities as part of CHURCH are 

AMENDED COMPLA INT- 9 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 9 of 28
in-part based upon BRANCH's location in Oregon. 

48. By seizing sacramental cannabis cultivated by BRANCH in Oregon where state 

laws allow for cannabis cultivation and where Congress has prohibited use of :funds for federal 

enforcement against medical marijuana, Defendants are discriminating against CHURCH by 

effectively denying it land use rights (i. e. cultivation of cannabis for religious purposes) based 

on a law of general applicability - the federal CSA - that prohibits all cannabis. 

49. Cannabis used for spiri tua I healing practices and in rituals of CI-IURCH is integral 

to the obligations CHURCH has with Native American Tribes and with its members. 

50. As a result of the seizure of its cannabis used for spiritual healing practices, 

CHRUCH has suspended BRANCH's cultivation, preparation, blessing and transportation of 

cannabis which has substantially burdened use of land by CHURCH, participation of members 

in CHURCH activities, associated transportation of members to and from CHURCH activities, 

compensation of members who participate in BRANCH's activities, purchase and use by 

BRANCH of organic components used to cultivate cannabis as well as other activities that affect 

interstate commerce. 

51. By discriminating against and thereby preventing CHURCH from cultivating 

cannabis on its land and transporting the cannabis used in its spiritual healing practices when 

they seized cannabis being transpotted to CHURCH members in another state, the Defendants 

have substantially burdened the Plaintiffs' free exercise and land use rights which has resulted in 

the affectation of commerce among the several States and with Native American tribes through a 

law of general applicability, the federal CSA. 

52. The actions of the Defendants described herein have divested CHURCH and 

BRANCH of cettain land use rights related to its religious practices and substantially burdened 

Free Exercise rights. Moreover, the Defendants' actions have affected commerce between the 

several states and Native American tribes. Accordingly, the Defendants have violated RLUIPA 

and the Plaintiffs seek injunctive relief as set forth below. 

AMENDED COMPLA I NT- 10 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 10 of 28
BASIS FOR INJUNCTIVE RELIEF 

Fed. Rule Civ. P. 65 & 65(b)(l)(A) 

53. Pursuant to Rule 65, this is a Verified Complaint. The Complaint and facts 

contained in it have been verified through declarations signed under penalty of perjury by James 

Warren Mooney, an officer ofPiaintiffCHURCH and PlaintiffGRA YES. 

54. The facts providing a basis for a temporary restraining order and preliminary 

injunction (Fed. Rule Civ. Proc. 65(b)(l)(A)) are those set forth in paragraph 1 through 

paragraph 50 of this comp laint and are more specifically set forth as follows: 

A. The federal government has seized cannabis used in the religious 

ceremonies, practices and sacraments of CHURCH; 

B. Without the sacramental cannabis, CHURCH and its members 

cannot perform certain ceremonies and practice its religion; 

C. The U.S. Supreme Court has deemed the CSA is not the least 

restrictive means of furthering a compelling government interest. 

The CSA was enacted to combat the recreational abuse of drugs -

prohibiting cannabis from CHURCH and its members who are not 

engaged in the recreational abuse of drug is not the least restrictive 

means of furthering the interest claimed by the Defendants; 

D. Among other members, a church member with esophageal cancer is 

waiting on the sacramental cannabis and each day delivery is 

delayed, her condition worsens; 

E. The seizure of CHURCH's sacramental cannabis violates both the 

RFRA and RLUIPA and as such constitute violations of the Free 

Exercise rights of the Plaintiffs protected by the Constitution. 

55. " [A]n alleged constitutional infringement will often alone constitute irreparable 

harm." Monterey Mech. Co. v. Wilson, 125 F .3d 702, 715 (9th Cir. 1997). Indeed, if an 

individual or entity faces threat of prosecution under an invalid law, the individual or entity 

suffers irreparable harm. Morales v. Trans World Airlines, Inc. , 504 U.S. 374, 381 (1992) (a 

federal cou11 may properly enjoin "state officers ·who threaten and are about to commence 

AMENDED C O M PLAI NT- 11 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 11 of 28
proceedings, either of a civil or criminal nature, to enforce against parties affected an 

unconstitutional act."); New Orleans Pub. Serv. , Inc. v. Council ofNew Orleans, 49 1 U .S. 350, 

366-67 (1989) (suggesting that irreparable injury is an inherent result of the prosecution of an 

invalid law); Chamber a/Commerce v. Edmonson, 594 F.3d 742, 77 1 (lOth Cir. 2010) 

(concluding that plaintiff is likely to suffer irreparable injury if enforcement of an invalid state 

law that is not enj oined); See also Villas at Parks ide Partners v. City of Farmers Branch, 577 F. 

Supp. 2d 858, 878 (N.D. Tex. 2008) (concluding that there is a likelihood of irreparable injury if 

enforcement of an invalid city ordinance is not enjoined). 

56. The Defendants will suffer little, if any hardship, if they are enjoined from 

refusing to release the cannabis seized by them. There is no evidence Plaintiffs have caused any 

public health, safety, or welfare issue and there is ample evidence showing the Plaintiffs are part 

of and engaged in bona fide religious activities. 

57. There are numerous constitutional violations set forth by Plaintiffs in this 

Complaint. The likelihood of Plaintiffs' success on the merits is substantial. As applied to 

CHURCH, the federal actions complained of herein are constitutionally infirm and violate 

specific federal laws that protect the Plaintiffs. Accordingly, the balance of hardships that must 

be weighed by the Court for purposes of injunctive relief weighs heavily in favor of Plaintiffs. 

PRAYER FOR RELIEF 

Plaintiff prays for relief as follows: 

A. For a Temporary Restraining Order prohibiting the Defendants from seizing 

sacramental cannabis of CHURCH and requiring the cannabis seized by Defendants be 

immediately re leased and returned to Plaintiff GRA YES; 

B. For a Preliminary Injunction prohibiting the Defendants from seizing sacramental 

cannabis of CHURCH and requiring the cannabis, if not then already returned to GRA YES, be 

immed iately released and returned to Plaintiff GRA YES; 

C. For a Permanent Injunction prohibiting the Defendants from seizing the 

sacramental caru1abis of CHURCH; 

AMENDED C OMPLAINT - 12 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 12 of 28
D. For costs and reasonable attorneys' fees pursuant to 42 U.S.C. § 1988 and any 

other applicable provision of state or federal law; and 

E. For such other relief the Court may deem just and proper. 

DATED: vi~tt 

R:iiCHAEL k '--ROSE OSB #753221 

Local Counsel and Attorney 

for Plaintiffs 

DATED: 1-15-2016 

AMENDED COMPLAINT- 13 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 13 of 28
VERIFICATION 

I, JAMES WARREN "FLAMING EAGLE" MOONEY, am the founder and spiritual 

leader ofthe OKLEVUEHA NATIVE AMERICAN CHURCH, one ofthe Plaintiffs in the 

above-entitled action. I have read the foregoing VERIFIED COMPLAINT (including each of 

the Exhibits to the Complaint) and know the contents thereof for the claims and allegations 

made with respect to the church and to me. I certify that the same is true and correct of my own 

knowledge for those things that I personally know in my capacity as founder, spiritual leader 

and officer of the church, except as to those matters stated upon information and bel ief, and as to 

those matters I believe them to be true and correct. Also, for those things that took place on 

December 10, 2015, I was not present in Oregon and so make such allegations on information 

and belief. 

EXECUTED THIS~ day of January, 2016 at Salt Lake City, Utah, United States of 

America. 

I declare under penalty of perjury under the laws of the United States of /\merica that the 

foregoing is true and correct. 

AMENDED C OMPL A INT- 2 

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VERIFICATION 

I, JOY ORA VES, am a member of OKLEVUEHA NATl VE AMERICAN 

CHURCH, and am also a Plaintiff in the above-entitled action. I have read the foregoing 

VJ<:RIFIED COMPLAINT (including each of the Exhibits to the Complaint) and know 

the contents thereof, and I certify that the same is true and con·ect of my own knowledge 

for those things that I personally know in my capacity as a member and branch leader of 

the church, except as to those matters stated upon information and belief as we ll as 

allegations made specifically and verified by another Plaintiff in this case and as to those 

matte rs I believe them to be true and correct. 

EXECUTED THIS ___6_ day of ~2 6 ~ (!}~'-----

Oregon, United States of AmMca. r 

I declare under penalty of perjury under the Jaws of the United States of America 

that the foregoing is true and con-ect. 

AMENDED C O \1 r L \ lt\ T - 3 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 15 of 28
EXHIBIT 1 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 16 of 28
g
EXHIBIT 2 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 18 of 28
Oklevueha Lakota Sioux Nation Native American Church 

ARTICLES 

The undersigned, Richard 'He Who Has the Foundation· Swallow, Chief of the S Landing Buffalo 

Band and Ch ief of the Eagle Clan of the Oglala Sioux Tribe of the Pine Ridge, United Stntes 

congressionally recognized American Nati ve Indian Reservation, and James Warren 'Flaming Eagle' 

Mooney Medicine Man of the CentrO! I Seminole People, hereby certify the following: 

A. OkJevueha Lakota Siou:x Nation Native Americ;m Church is an Allied and Communal Native 

American Churcll merging the Lakota Sioux Nation Native American Church and Oklevueha 

Earth Walks Native American Church of Utah Inc. of the United States. 

B. James Warren 'Flami ng Eagle' Mooney and Richard 'He Who Has the Fouod01tion' Swallow nre the 

co-founders of the Ok1evueh01 Lakota Sioux Nation Native American Chun:h. 

C. The Great Spirit that manifests itself with each member as they walk prayerfully is whilt guides all 

<~ctivities and affairs of the Oklevueha L<Jkota Sioux Nation Native American Church. 

D. Symbol and/or representative logo for Oklevuehil Lakota Siou.'\ Nation Native American Church. 

E. R.ichBrd 'He Who Has the Foundation' Swallow of the Lakota Sioux Nation, is the Custodian of the 

Medicine (Ceremonies. Sacrament or Eucharist) of the Oklevueha Lakota Sioux Nation Native 

American Church for the remainder of his walk on Mother Earth. 

F. The co-founders aclmowledge Oklevuella Lakota Sioux Nation Native American Church Code of 

Ethics is to be a guide in assisting the activities and growth of Oklevueha Notion Native American 

Churcb. 

G. R.ichurd 'He Who Hos the Foundotion' Swallow, Custodian of the Medicine ockoowledges by his 

passing (meaning to being deceased) sl10uld he not have previously oppointed il Custodian of the 

Medicine of the OkJ evueha Lakota Sioux Nation Native American Church, the following \vi ii take in 

effect. 

H. We odvisors ofOklevueba Lakotn Sioux Nation Native American Church aclmowledge that R.ichard 

'He Who Has the Foundation' Swallow' has been appointed by the Greilt Spirit to be the Medicine 

Custodian ofOkJevueho Lakota Sioux Notion Native American Church, and with our signatures we 

accept to honor all stipulations A - I of these Artieles; 

rincjpg,p~ee Agents 

I. Boarue 'Winyon Waste' Swallow 

l. 

2. Eva 'RiverOwl ' Fernandez 

3. James Warren 'Flaming Eagle' Mooney 

4. Lindo Taylor 'BrightHawk' Mooney 

5. R.ichard 'He Who Has the Foundation' Swallow 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 19 of 28
Oklevueha Lakota Sioux Nation Native American Church 

ARTICLES - STIPULATIONs· 

The orune of the this Native American Church is Oklevueha Lakota Sioux Nation N~tive American Church 

A. Ok.levueha Lukotn Sioux Nation Native American Church is an Allied and Communal Native 

American Church merging the Lakota Sioux Nation Native American Church and Oklevueha 

Earth Walks Native American Church of Utah Inc. of lhe United Stales. 1l1is said Native American 

Church is also known as Ok.levueha Native American Church (Native American Church and I or NAC) 

B. James Warren 'Flaming Eagle' Mooney and Richard 'He Who Hns lhe Foundation' SwOJI Iow, CIUefof 

the StOJnding Buffalo Band and CIUef of the Eagle Clan oflhe OgiOJia Sioux Tribe are the co-founders 

of Oklevueba Lakota Sioux Nation Notive American Church. 

James Warren 'Flaming Eagle' Mooney 

A)?;6~< -· ·~· 

Certificate or Ancestry 

James W. F. e. Maonov 

"' -"''"' "" .,. c;.. ..J ..... ..,._ • ._,..r_o: __ ••r,.,. .... .....__ ~ 

On ~t l~ 

·- ·•tf'o.o.l- •--•urnRichard 'He Who Hus lhe Foundation' Swallow ,. .: 

Oep::.rcmcnc or Enrollmenc '" ... , .... ,.,_,,......,. , _ ,.o_ .,. nn •. ,.,,.., ..... - .. ,-. 1:1 11•, ...... ~.._ .... , _, ..,, 

I ..._u, .....ulrl U.ol ~ C'1 UDt -a> \..1 Uo~w" t:. Jl ... IIAI'o 

:~ ::7:~:·: :::,::_~ ~.J :::;·:.; ::~:. ~ Uiltl ..J - ... w . .. , D , IIH 

I 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 20 of 28
C The Grem S~mtlh~· m~tnife.sts 1tscll with each member as they walk prayerfully is whlll u.uldos oil 

Cl:ll\'J:'e:. anc a!I:HI'$ or du: Oldci.'IJChJ Lo.kolo SIOl~ NJtlon Native A.meric;~n Church. The duily, 

we.UJ)-. ~U<Uler' 'i and )aNY affairs ofOklt:vuclu NJnwc Amc.ric:la Coun::h nrc ulMnecd in an allied 

communa] mlllllltt !hal is QdUsl\cl}rled b. ll1c (j, t SpmL 

!) Jnme..'i Wanen 'flamina Eagle' Mooney and R!ch.lrd 'He V'no Has the Fo~daf1 o' S \low. 

Oldcvueha N11tlvc American Clnm:b co-found::n ac O')Owledgc this syrnbolto be the rep~m.a;he 

logo for Ok.levllclm l..nkOUI Sioux Nation Naovc A.mcncan Chun:h 

E. Richard 'He Who H "the Foundation' Swi11Jo'" or the Sioux Nation. is the Custot.ha:n o: 6~ 

Medicir1e (Cert:rnomc: , S.1ci11ment or Euc.han:.t) (If tl.c 0 · evueb.1 La'<ou s ·ow. r\~tion.' u c 

American Church for !he .ramntnder ofb1.s wnlk on Mothc:r Earth. Custod.;m o( U. ~·!:&he ne pr: r.ary 

n.:.sponsilJiliry l!i ~ Jollowl!n.. 

l. .Maint.nio the integrity of ull Olclevuc:ha Native Ammcill'l Chun:b CcremonJes 

u) Ovc~ec all OkJcvueba Native American Church ceremonte~ conducred :n 

ConadJ.. lndiao Rescrv;llloos, Mexrco, and the UnJied Slmcq of America 

b) On:.~ce a!J leachins:. ofth~ Oglnln Lakom Sioll .. '\; Spi1i11m1 I mtl{buns 

2. Pro~Jde.1JI Ok!.::wel'-1 NatJ\c .\rn<:r:r:an Churd1 Sacr.rr.cna or E11crult'JSI for all 

O'dc-.~clu Nat.\c Amcn:-.an ChJrches m Cenada. l11dJilrt Re!icr~·t~ io s, Mexico, 

and t.be Unit!:d StniCl of Aru:nc;, 

tt} Cuhi,crion 

h} Harvesting 

c) Distribution 

J. Rely on lhc United Sli111:ll OovcrnmeoJ IO ;:rotect OkJe, cha N;]~\-C 1\:.Jieric.m 

c"hHI'l:h rightS 10 worship us ~, \JI incd in the First Amendment of the • Jnitcri 

Sttlles Constitution nod more c:lcnrly outlined in the RcligiouJ Lillie Usc Md 

lnsumuoo.1lized Pcrsoru Acl of2000. 

F. rn~ ro-fcu!lders ild I 

Etftics !o b~ a guil!c to 

~teLl c: Ok:e'r-~c:b.! l...L-:Ql.l ' u1ux. 3::!on Native AmetttiiD C'hurch Code of 

!!:1 in the ~cri\'zti::s .•ud t;ro"' Ol Oklcvue.na Nt~tr"e Amcncan C'hurch. 

0 lcvucha :-!atJve AIDe~ CL.uc:h Coee vfEthi::& 

Ok lt:vuchu No•lvc 1\mcmc:nn Church ottcplS pcyo·c ;u ec:."r.!\ to 115 ~~~ rr '' s ~I d P<:>'(!::.: is ·..m: 

signfficant tai:Tllml!nt fur this church. Howe\•er, Ol..lcvuehe N11hc ,P."'M:f.c;m Qr.rch be rl~""l'! II ~ .J~1!ll'r.d 

So~:h Anu:ntr.tl 'acivc fllc:hori5.t's SJJch a!J 1\ yohuo~o. !i n Pedro, Tii-A hg>~. WaoCJ tutd nr 

The IJ:JH1cs fq)'ltH: ut.•f.tli~tr.~tnrs oft!lese 5ilCI'tl lllcnt ~ "•II')'. Some of the nrunt.-s !hoc ndmlnlstmtors ore 

ic':oWI; by t!t1l c.s. (ut'u\'s. C.Jn!J::dt:r.~. El<!a, OI:<Ht t.~cc Oticf, Mruil'aknrne, Mc:clirutc Mnn/WomJn, ries ~ 

Rabtn. Rc\'l::n::nd, S~oce P1:Jc: Carner, Shlll'l11l/'1, Sun Dlll.cc: O lltf. Warcr Po11rcr, C'IC. We call auch JX'Oplc 

'Spin lHill l.t'Jf!\ln tho;c: \4'!1io :rn: '!;X!l=::'l~ n ~o:nc: J\mc:rit;m N:rtivc S;Uri:uol prot:• lee•: >~ d who :tel 10 

focilitJIC lhc ~ n"\.0.;. pr.Jeitn of 0~ A1 a~ rvuc ,_ '!.11\.l: Amcri:.m Q;J~b splnHJ3! 1t!ldCJ II'CCO not 

clr;im clCdt~: i•·c t dr!ir.uh c lcoow~ge ofl ' ,. he: p~;.l -~ Eren !!lC'tJ;:J o··'cvvch:t Noel IIC Allleric:un 

C'\un:h's flTlftU!I}' ~,;.p()!e ,, lo ::!Ciminis·c:;- S;;~~·cniJ cc::"!:"'''Qn ~ Ml 0.-;lcvu.:::u ~· \(C o\l:lC'Il(;.m Churd . 

spiritunl k::~d~r i:; fn:.t lo nor cdministcrl iDtmi'IO'II u dnt- .1 p.,!ta:Jf Amcrl:.l1 "'Jit\c r:.aOT ooy 

All <:ct .:m k~. ~)Ttelllll)' I he Sun D~n c:. s\\ l.colc.tce .uld Visiatl Qc~ cry :.Otr'c.: cn:o:tonni Cl!C 

pl!y~ic:II risk~. rl:ereJore, when a member ll!ldlor "' tiiDJ il n~ntJ::nt::" :;h(l()!d:S to Pi>t11';1p 1.. 111 3R A:nc:ia; 

'Ia It' c Ceremony wi1h the ussistcr.CA: of on Okl;:\ •·~ ,..,Jii\'e Atr:c:::ic;m Otur::h ~plnltiJI lru:kr. ba_-: b...~ a 

on spcr:.iil i'C.'lpo-rt.5 bilirie~ Some of 1ho.sc rcsponsibihtle5 nrc ar. rol!ow£: 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 21 of 28
I. Oklc:vueho N<~live Ameri~an Church spiti tu a.l le.:~das are 10 practice aJI<I serv~ in ways that cultivate 

awnret~ess, empathy, nnd wisdom for-all members nnd visiting panicip:111ts. 

2. Oklcvucha Native Americ:ut Churt:h spiritual prildicc:s arc inspired and conducted in woys thor respc:ct 

lhu common good, with due reganl for public s;)fccy, health, and otu.cr. Often, the increased awa.r :s~ 

gained from American N<lli\<'c Spiritvol cl:r'emonie:~ '"ill c:ntaly-r.c n desire for pl"''SOnal and social change 

in 11 member and/or visiting pr.x:titiooa's life. Spi.ritllDllcnders shall usc special cnre in assimng the 

direciion of energies of those whom they serve, as well r.s their own enerei.s. in responsible wnys that 

renect a loving nnd respectful regard for all life. 

3 . Oklevuehn Native Amcricnn Church spirirulllle;:dm ~lJe::: nnd seek to pn;:.ervc the uutoncrny and 

dignity ofenc:h member nnrl visiting pl!rtk:ip:lllt. P:micip31ion in III\}' Okle~uc J': Native Anu:ricnn 

Church Ceremony mU$l be ~O lll Uy and b~-d on prior disclosure [lnd consent given by c:t~c h 

r-nnicipanl whfle in an ordinary StOle or consciousness. Oi ~dos re sholl ud . alo minimum, 

discussion of ~my elements ofth:: ccrcmony thot could f"..asonably be £ecn as prt:Scntinc physico! or 

psychologit'>ll risks. In pO!fticuiDr, visiting practitioners must be wnrned tllat Americun Nntivc 

Ceremonies C!;!IJ be difficult llfld dr:unatia~lly tro.nsfom1in.r.. Spiriruai le<~d crs shu! I mnk~: roJSonltble 

pr,epnrnrions 10 protect C(U:h pa.rricifJllnl's health lllttl ~1 fety during the C1!remony and the few hours o[ 

vulnerability thBt may follow a ~m:m n>'· Li.r:!iL<r Oflthc behoYiors of mc:1nhc:~ ~mel visiting proc(itioners 

und spiJitunl lcnders nrc lo be mode clc:m- on<l og.-eed upon in ndvnncc oi uny Arru:ri<:un Noti ve 

Ceremony. Culrurol a.'!dnligious custOOE and o:~ fi denti lity ru-e 10 be Bcc~-p:cd nnd honored. 

4. Okleweho Notive America., O!urch spirit:uol le-aders ilJI! 1\WJ.rc during ceremony thm memht.'n und 

visiting pracdrion'!r:; may be es;JcciRlly open ro suggl!l.tion. Le.1t!m pledge lo prol!:ct pllrticipnnts untl 

nol to allow un~o nc to usc thel vulnerability In ways thot harm themseJves or others. 

5. OklevuehQ Native American Choo::h is comrnille:rl to to;mwth thrnugh ntrracriou of se-rvice ruther tlHU\ 

active proselyti-riog for cm~hip. 

6. Oklcvueho Nnlive Amcriciln Church ccn:monics an: to be conducted in the spirit of scn~c~;. Spirinml 

Le11dm cccommodntc membt:rS .il!ld visiting pm1;1irioners wit.'Jout rcgnrd to race:-, rdigiou:; ffi in ion~. 

ger.dcr, r;;u lrur.:tl bnckground, fillarlcitll !ii;)lUS, and/or poliricolaffiiiilrions. 

7. Oklevucha Nmtivc Amoricllll Chu.reh is srrfcrly a Spiri:ual organization 1h n1 SC:"YCS indivicluuls ond the 

1vidcr community, nnd makes absolutely no claims abo.l.l( hc:ing in uuthorily or hu~oing h~ !lbllhy to 

oomlucl.&llv:ins ord imm~ 

"II is time to share QJc Cl..'TCTllonie:s with oil people'' - Seminole Chi~f Lillie Do•-e 

.. Never deny illl)'One lhnl I!.Sics for he lp"- LtJJ:ota Stou.f" Roodman L!;:sii!i'. Fool Bull 

G. Richurd 'Hl! Wbb Has the Foundation' Swilllow, Custodian of £he Mc.:tlicine ndcnowJedges by his 

passing (menniDg to bcislg deceased) should he not h<we pn:v!ous1y appo inred n Cuslodi11 o of Lbe 

Medicine of the Oklevucbo Lakota Siou~ Nation Native American Cburcb.. the followi.;, g will take in 

effect. The surviving Advisors wiU unanimously ap.poiot a pc:r.;oo to be bcsto\ved of this S!lcreti 

calling. This meaning be or slae that is nppoimcd will reside over oil spiriruul and ropor11J 

proceedings ofOkJevtJeha Lakol.3 Sioux Nnriun N11tive American Cbureb according to aU th<: 

stipulations oullli:led in A - L 

I L We advisors ofOkJ.svueha Lakota Sioux Nation Native Arnerican Church acknowledge that fticbMd 

'He WlHl Has the Foundation' Swallow' hilS been appointed by the Great Spirit to be the Medicine 

Custodian of Oklevm!ha Lakotu Siou;( Nation N ative American Chn.""Ch, and wi<b our signntures we 

acceptlo honor all stipulations A- I of these Articles; £l/;tf 

L B<lnnie 'Winyau Wn&lc' Swru\ow of Qgb! Sioux Arnericnn 'Nntive Blood linoge, of the Pine 

Ridge Reservation .-:t; · . i. · • I ~ l 

4. 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 22 of 28
5. ;)tioo and Oklevueha Earth Walks Native American Church ofULah Inc 

~~~:M:=-'~1/, -""'b-.,r- ~· · ,_._'-l__k}ll[ .ClLc41-t-~tS::..ffl'l I.So'-'IT!-1 Olflr<o-r~ 

11. ) an '1'\ £r:b f/P.Yt___.!_IY:~E ______ _ _ 

12. Wyv'lt.lk'J lJhl.l!J 9f4J.L~t ~Or d:\, p "'! v<a +-~\ 

13. ~ t.dla.ll ,p ~., ... f/J2, k.u.;..af-.J;;; A;.l..__ _ _ _ 

l. Principle AgcnLq 

/_1 ' b, FlJ,·d .· ~c/Jc/'6-r//tL) Be:::lllle Wtnyan Waste 'Bear Kil.er' Swoliow 

P.O. Box 84, Wounded KDee, Sout11 Dakota, 57794 

Pho c Numb~r~ 308 4 0~3927 

va R.iverOwl' errumde£ 

151 Lake Kcorud:y, El Paso, 'fc;(;}S. 79 ? 

Phono Number. 915 852~3971 

Cell Phouc: 9 I 5 526-7314 

~~.~ := w:;.n 'FI=in:i' Mooney 

1559 South 1460 East., Spanish Fork, U1aJ1. ll4660 

Ph{lne Number~ 80 ! 427-1 272 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 23 of 28
We dn: Co fO:.Jnr.~, of OkJ.e,,.dl l.a<OQ Siou.'t. Notion Native Amerienn Church l.tnvu personal 

lmowl~_cc of lhc fncu ofthae Okle·."U6'a N.,uve <1.roenom Church Nude~ !lJ1d Artie le Sripula1ions with 

our &tgllllD.!I'e we ookn_o\v1edoe th::se ds Lobe true und n:oou:mte 

( - , (.' r. f - I!, 

• I / L!.- \_, t 1..-

Rithft! 'flc Who H.tS 1!1~ rOJJodation' SwnlJow 

Co-Fonndl:l ruld I~L::tru: Cusrodia£ 

0. lev\:du 111hc Ant::fl 01urc!l 

Subscribed tlbd swotll lo, before me !hi'S' __j_J_ :Jny of 19!k&.....e,._ • 10 o 7 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 24 of 28
EXHIBIT 3 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 25 of 28
\1 lJ: •• N1TTVJ:. c~o .~1''1 10 

TM•& f-'t10CLAio/t~TlON av ANO SET~·~~ JA •1£::;:1 'Fl.;AMING EAGLE' ,_. OO·~t, Y' Or 

THE Ot{t..I:..\IU~~A N..:.·nvc A.l'1F:RtCAN C•-itJF=~c._. o·· H VNI~ STA1 t.S O"' 

AME RICA 1\ND T A l A .Jose, Ht"RI'JANDE.Z SANC I~ OF 1 f-IE ~UICHGL F or"' A 

YF'!:i \"A NAYARIT ;.,.1E:.XH: O HE'RF(I'r S~VE.':> A!i .,,,;-: r:)FJt'lCH'i.o... CE.R"rf""''lNG 

DOCUM[:.Ni FOR THE Uf\JIF"ICAi ION OF PURPOSE T O Sf'RVE Jr'llOIGt:'NOU:..> E t-DERS 

Or NOPTH AN:: SOUT H .0,f;lttt:RICA A NO YOUT,_. iOWAPO A Se-TTER 

NO£:.~~ T'ANDtr-.G OF NIVt: >l::. S~ll=liT AND THC'<JO t-.1" AND TO S.HAJ"fl:. - , tC'.;< 

WAY$ 11TH ALL Pi;OF't !"!:';-AN~ f•"IY: ul'\lt TU:;:~ RECArt t ~iSS OF !3EL.tE..F . R/4CE:, 

ve.f.p ctJ OR .s;:>c••L s>AI'I JNO 

T ... Ro•.JCH c.. ::E:~~o N" co~!:luc-:::o aY OKu:vu · A NA'TlVE A'v!E:Rt=~"J 

Ct1 1.,; ~CI"i CUSTO~N'-1 o~· 111E !;:. CH~1:5T ~ OAr.· 'IELl-ICV/ SIRO D"EJl,R,._.O'("' ANO 

tj·,• ti .. NNINO ~vt-H E:A8• t' ,,_ r:. A,.Hf:r:I'S, F~f\ cu~.!l(l~t. Or i':IQV\Ie;R TC 00 f'Ofh.•i.JoRD 

;.'H.:!J Wl1 1-f O IRCCTJON. WITH EH~e.AThTO fi\~E.J-\Tl .. , Ht:A~--o HEARl Af'VO 

CLA~P NG ARMS. WITNF.:!:i:::;r:D 9YThE C:~ .o, ro~ f-lR!;:, 'W ANb OUR 

O PGANIZATIO"\JS, FROM n ... OC f'10MENY'S 01\. ANO AS 1.-0rJG, AS 'TI-fE q•VCr.{S F'\ ... OW 

.Af'JO THE CRASS GROW_,, WAL K TOG~HF.:~ ()N TI-ll$ EARTHLY JOURNEY AS 

'5E:')V.O,NTS. WITH THE' ~1'\IC t,. t! FUR =>os~ OF 9£f1V•NG TI-t~ GRE:AT S,..,I~IT 5 

C RC.A1ION OF '-'10 1 >1£::.11 1\•~ I H. F'ATHE:R Sk't A'>ID ALL T'--'E;IR Ct-tlt..ORE:"r ''llliH 

;=;'C":.;:;'ECT AN:> H·;:.~OfJ 

/ / I< Ill .,. -----

· NGX ,. - -.o 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 26 of 28
EXHIBIT 4 

Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 27 of 28
English Customer Service USPS Mobile 

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Tracking Number: 9505514178015344132275 

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USPS Tracking Tu 

LOCATION 

PIF .1se contact the U S Postallflspect1on Serv1ce for further tnforrnatlon. 

December 11 , 2015 , 5:40 

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Departed Post Office 

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Case 3:16-cv-00077-BR Document 7 Filed 01/21/16 Page 28 of 28