National Indian Gaming Commission 

NOTICE OF VIOLATION 

To: Ivy Ong 

C/O Bill Price, Esq. 

Phillips, McFall, McCaffiey, McVay and Murrah, P.C. 

1 Leadership Square, 12~~ Floor 

2 1 1 N. Robinson 

Oklahoma City, Ok 73 102 

Ivy Ong, Manager 

Carlo World Wide Operations, LLC 

220 N. Main Street 

Seminole, OK 74868 

Gordon C. Richards Professional Corp 

Nevada Resident Agent for Carlo World Wide Operations, LLC 

1850 East Flamingo Road 

Suite 204 

Las Vegas, NV 89 1 1 9 

Notification of Violations 

The Chairman of the National Indian Gaming Commission (NIGC) hereby gives notice 

that Respondents Ivy Ong (Ong) and Carlo World Wide Operations, L.L.C. (Carlo) 

managed and had a proprietary interest in the blackjack and gaming machine operations 

of the Seminole Nation of Oklahoma (Seminole Nation or Tribe) and are consequently 

in violation of the Indian Gaming Regulatory Act (IGRA), 25 U.S.C. 4 2701 et seq., 

NIGC regulations, 25 C.F.R. 5 501 et seq, and the Tribe's gaming ordinance. 

Under IGRA and NIGC regulations, the Chairman may issue a Notice of Violation 

(NOV) to any person for violation of any provision of the IGRA, NIGC regulations, or 

any provision of a tribal gaming ordinance or resolution approved by the Chairman. 25 

U.S.C. 8 2713; 25 C.F.R. 5 573.3. A NOV must contain a "citation to the federal or 

tribal requirement that has been or is being violated." 25 C.F.R. 8 573.3@)(1). 
Applicable Federal and Tribal Laws 

IGRA requires that tribes obtain the approval of the NIGC Chairman to 

enter into a management contract for the operation and management of a 

gaming operation. 25 U.S.C. $ 271 1. 

NIGC regulations reiterate this requirement, mandating that "[slubject to the 

Chairman's approval, an Indian tribe may enter into a management contract 

for the operation of a class I1 or class I11 gaming activity." 25 C.F.R. 

8 533.1. Management contracts become effective upon approval by the 

Chairman. 25 C.F.R. § 533.1(a). 

All management contracts not approved by the Secretary ofthe U.S. 

Department of the Interior must be submitted to the NIGC for review upon 

their execution. 25 C.F.R. 5 533.2. 

Management contracts and changes in persons with a financial interest in 

or management responsibility for a management contract that have not been 

approved by the Secretary of the Interior or the Chairman are void. 25 

C.F.R. 5 533.7. 

NIGC regulations provide that it is a substantial violation of IGRA for a 

management contractor to operate a gaming operation without an approved 

contract. See 25 C.F.R. 8 573.6(a)(7). 

IGRA provides that, to lawfully operate Indian gaming, a Tribe must submit 

for approval to the NIGC Chairman a tribal gaming ordinance. 25 U.S.C. 

9 2710(b)(l)(B). 

The IGRA requires that the tribal gaming ordinance must provide that the 

Tribe have the sole proprietary interest in and responsibility for the conduct 

of any gaming activity. 25 U.S.C. §2710(b)(2)(A); 25 C.F.IR. $522.4@)(1). 

NIGC regulations require that a tribe's gaming ordinance provide that "the 

tribe shall have the sole proprietary interest in and responsibility for the 

conduct of any gaming operation.. .." 25 C.F.R. $ $ 522.4,522.7. 

The Tribe's gaming ordinance, approved by the Chairman on May 3 1, 1999, 

provides that "[tlhe Seminole Nation shall have the sole proprietary interest 

and responsibility for the conduct of gaming activities conducted in Indian 

Country subject to the jurisdiction of the Seminole Nation.. .." Seminole 

Nation Public Gaming Act, Title 15, Section 11. 

One has a proprietary interest if he shares in or derives profit from a 

business as opposed to being a salaried employee merely performing clerical 
and ministerial duties. Dondlinger v. United States, 1970 US. Dist. LEXIS 

12693 (D. Neb. 1970) 

IS. The common, ordinary meaning of "proprietary interest" is "one who has in 

interest in, control of, or present use of certain property." Evans v. United 

States, 349 F.2d 653,658 (5" Cir. 1965). 

L. Failure to comply with any provision of an approved ordinance is grounds 

for issuance of an NOV. 25 C.F.R. $573.5(a). 

Purpose of Approval of Management Contracts and Sole Proprietary Interest Requirement 

The operation, management, and control of the tribal gaming operations by Ong and Carlo 

without a management contract approved by the Chairman and in violation of the sole 

proprietary interest requirement threatens the NIGC's ability to achieve its congressionally 

mandated goals of shielding the Tribe fi-om organized crime and other corrupting influences; 

ensuring that the Tribe is the primary beneficiary of the gaming operation; and ensuring that 

gaming is conducted fairly and honestly by both the operator and players. See 25 U.S.C. 

9 2702(2). 

Circumstances of Violations 

1. The Seminole Nation is a federally recognized Indian tribe with headquarters in 

Wewoka, Oklahoma. The Tribe owns four gaming operations, two of which are at 

issue here: the Rivermist Casino (Rivermist) located in Konawa, OK, and the 

Travel Plaza, located in Seminole, 0klahoma.l The Tribe has operated Rivermist 

since the spring of 2000 and Travel Plaza since approximately October, 1998. 

2. The Seminole Nation Development Authority (SNDA) is a duly created agency of 

the Seminole Nation granted authority and responsibility by the General Council of 

the Nation to manage and operate the Nation's gaming activities under the 

provisions of the IGRA. 

3. Carlo is a limited liability corporation registered in the State of Nevada. The 

corporation was originally registered on or about April 20,2000, and its status was 

revoked on May 1,2005. Carlo's registration was reinstated on or about June 20, 

2006, and remains current. Carlo, in its corporate filings, currently and prior to 

revocation, lists its principal place of business as 220 N. Main Street, Seminole, 

Oklahoma. 

4. Ivy Ong is listed in the Articles of Organization of Carlo as a manager. In Nevada 

State filings of the Annual List of Managers and Members of Carlo, Ong is listed as 

a manager for the periods April 2001 -2002 and April 2002-2003. 

- - 

1 The Tribe's other operations, the Seminole Nation Bingo and Casino and the Wekoka Trading Post, may be 

mentioned in documents in the agency record, but are not at issue in this case. 
5. The Chairman of the NIGC has never approved a management contract between the 

Tribe and Ong or Carlo. 

6. On September 27,2001, the Tribe requested that the NIGC review agreements 

between the Tribe and Carlo to determine if the agreements were management 

contracts requiring review and approval of the NIGC Chairman. On May 7,2002, 

the NIGC upheld the determination of the Chairman that the games that were the 

subject of the agreements were Class I11 games and therefore illegal as no tribalstate compact existed between the Tribe and the State of Oklahomi allowing the 

Tribe to operate Class 111 games pursuant to 25 U.C.C. $2710 (d)(l)(C). On May 6, 

2003, the NIGC advised the Tribe that it would not review the agreements because 

they were void for illegality. 

Wizard Gaming Machine Ameement 

On January 21,2000, prior to its relationship with Carlo, the Tribe entered into an 

Operating Lease Agreement with Wizard Gaming (TribelWizard Agreement), an 

Oklahoma gaming machine company. The Tribe/Wizard Agreement provided that 

Wizard Gaming would install gaming machines in exchange for forty percent (40%) 

of the net win hom the equipment (machines). Net win is defined as cash from the 

bill acceptor minus payouts fi-om the machines. The TribeIWizard Agreement does 

not specify at which location the gaming machines would be installed. However, in 

2000, the machines provided by Wizard were installed at both the Travel Plaza and 

Rivermist. 

8. When Wizard games were first placed at Travel Plaza and Rivermist, MultiMedia 

Games, Inc. was the only other vendor providing leased games at Seminole. 

Carlo Gaming Machine Aaeements 

9. On August 16,2000, the SNDA and Carlo entered into an Operating Lease 

Agreement for gaming devices at the Rivermist gaming operation, and on 

September 11,2000, the SNDA and Carlo entered into an Operating Lease 

Agreement for gaming devices at the Travel Plaza gaming operation. 

(collectively, the TribeICarlo Agreements). The TribeICarlo Agreements 

provided that Carlo would install gaming machines in exchange for forty percent 

(40%) of the net win from the equipment (machines). Net win is defined as cash 

fi-om the bill acceptor minus payouts from the machines. The TribeICarlo 

Agreements are similar to the TribeIWizard Agreement in other respects, but 

contain several key additional terms. Those additional terms are that: 

A. Carlo would pay for the cost of construction of new gaming facilities at both 

Rivermist and Travel Plaza, with no requirement that the Tribe repay Carlo 

the costs of construction; 
B. Carlo would provide, at each facility, two full-time managers and two fulltime technicians to assist in training of employees and management of the 

facility, and that these employees would be paid by Carlo; 'and 

C. the length of the TribeICarlo Agreements would be one year, with the option 

of Carlo to extend for seven additional years. 

Rolen Miller of Wizard Gaming reported to NIGC Field Investig,ator (FI) 

Marcelin R. Pate Ober that, approximately 6 months after Wizard and the Tribe 

entered into the TribeIWizard Agreement, he was told by Qazi Alam, Executive 

Director of the SNDA, to "cut a deal with Carlo." 

Consequently, on July 15,2001, Carlo and Wizard gaming entered into an 

Operating Lease Agreement (Carlo/Wizard Agreement) for the installation of 150 

gaming machines at the Tribe's Travel Plaza gaming operation. This agreement 

was in form and substance similar to the TribetWizard Agreement but for three 

key provisions. These provisions are: 

A. The term of the CarloIWizard agreement was one hundred and eighty days, 

renewable for one year and for successive one year periods thereafter; 

B. Carlo would pay Wizard twenty percent (20%) of net win; and 

C. An employee of Carlo would obtain meter readings on the games provided 

by Wizard, and Carlo would forward those readings to Wizard, along with 

payment for the percentage split of the profits. The CarloNVizard 

Agreement is silent as to any responsibilities of the Tribe for operation, 

maintenance, or accounting of the machines. 

On November 15,2001, Carlo and Wizard entered into an Operating Lease 

Agreement for the Rivermist Casino. This agreement was identical to the one 

the same parties entered into on July 15,2001, for the Travel Plaza operation. 

Casino Expansion and Desim 

Carlo was instrumental in financing, renovating, and expanding the Tribe's 

gaming operations. As provided in the August 16,2000, Operating Lease 

Agreement for gaming devices at the Rivermist gaming operation, and the 

September 1 1,2000, Operating Lease Agreement for gaming devices at the 

Travel Plaza gaming operation, Carlo paid for the cost of constructing new 

facilities at both locations. Carlo claims it incurred costs of over $2 million for 

construction of and equipment for the Travel Plaza facility, and over $1.3 million 

for construction of and equipment for the Rivermist facility. Carlo also paid 

related costs of advertising, consulting, and attorney's fees. 

14. The expansion resulted in room for additional gaming machines and blackjack 

operations. 
15. Jon Rooks, a manager for Carlo (Carlo Employee Rooks), was involved in the 

layout design for the new facilities. 

Operation and Management of Gaming Machnes 

Roy Yargee, an SNDA employee (SNDA Employee Yargee), was the Gaming 

Manager for Travel Plaza fiom approximately November of 2000 until March of 

2001. 

Nettie Haney, a SNDA employee (SNDA Employee Haney), was the Interim 

Facility Manager for Travel Plaza beginning approximately late August or early 

September, 2001. 

Carlo owned the machines and decided what machines were installed and placed 

at Rivermist and Travel Plaza. SNDA Employee Yargee had no :involvement 

with machine placement. 

Carlo's machines were placed in prime locations that other vendors also wanted. 

Carlo had 70-80% of the floor space at Rivermist. At Travel Plaza, Carlo had 

about 60% of the floor space. Most of the remaining floor space was devoted to 

gaming companies that were paid through Carlo. 

Carlo Employee Rooks managed the gaming machme operations at both 

Rivermist and Travel Plaza. He oversaw the machine technicians and gaming 

machine orders at both locations. 

According to Lany Brown, Security Officer at both Travel Plaza and Rivermist, 

the security department reported any issues with the machines directly to Carlo 

Employee Rooks. 

Miller stated that any changes to the machines or movement of the machines 

within the casino were directed by Carlo. He further stated that any operational 

issues went through Carlo and that Wizard received all of its direction from Carlo. 

Miller stated that Carlo Employee Rooks was usually the person with whom he 

dealt. If there were any technical problems with Wizard machines, either Carlo 

Employee Rooks or a Carlo machine technician would call Wizard. Miller dealt 

only with Carlo on all business decisions or discussions about equipment in the 

casinos. Miller believed Carlo had a management agreement with the Tribe. 

Carlo supplied its own full-time on-site technicians to set up the machnes, 

configure the software, and train casino employees in running the reconciliation 

software. No other gaming machine vendors provided I11-time on-site game 

technicians or had a manager on-site at the casino. 
Maintenance of Gaming Machine Records 

24. Independent auditor Dennis & Company CPA's, LLC, (Dennis & Company), in a 

November 25,2002, letter to Qazi Alam, identified as a "major issue" the 

reporting of gaming machine revenue. The auditor concluded that the reporting 

of machine revenue was not in compliance with NIGC Minimum Internal Control 

Standards (MICS) and that hard meter readings were kept by Carlo and that Carlo 

billed the SNDA for those readings. The auditor fbrther noted that the SNDA did 

not monitor the hard meters. The auditor recommended to the SNDA that it 

monitor the readings not only to comply with the MICS but to verify Carlo's 

billing. 

25. Carlo Employee Rooks created a computer program to check hard meters and 

theoretical hold on the gaming machines. For a period of time, he also inputted 

the numbers into the program. 

26. Carlo and Wizard split the vendor's 40% fee, with each receiving half, or 20%. 

At first, Wizard invoiced the Tribe for their share of the fee and the Tribe sent 

payment to Wizard. Later, Wizard invoiced Carlo directly and received payment 

directly fiom Carlo. 

Blackiack Operations 

Financial Arrangement 

27. A February 7,2001, "Agreement of Understanding, Blackjack Commission 

Distribution" between Carlo and the SNDA provides that the conlmission, less 

salary and wages of pit bosses, dealers and valets, shall be divided 60% to 

SNDA and 40% to Carlo, less 20% of the costs of soft drinks, coflee and chips. 

This agreement was followed by the parties until Carlo left the Seminole gaming 

facilities in August of 2002, and casino records reflect this arrangement. 

Establishment of Blackiack 

28. During his tenure, SNDA Employee Yargee had no responsibility over the 

blackjack employees. He did not set their schedules, nor did he have authority 

over training, discipline, pay raises or promotions. He did have this authority 

over tribal gaming employees. 

29. In approximately August 2001, SNDA Employee Haney was promoted from 

casino clerk to Interim Facilities Manager at the Travel Plaza. At that time, she 

advised Qazi Alam that she did not feel she had the requisite experience to 

manage blackjack. Alam told her she did not need to supervise blackjack because 

it was a separate operation. From August 2001 until Ong's departure in August 
2002, SNDA Employee Haney did not manage the blackjack games or 

employees. 

Ong planned the new blackjack operation at the Travel Plaza. No one at the Tribe 

had blackjack experience. 

Ong had access to all areas of the casino and its offices. 

Carlolong supplied blackjack equipment. 

Ong decided the number of tables, how many and which machines to remove to 

make room for the tables, placement of the tables, and the rules for the blackjack 

games. 

The first blackjack tables were established at Travel Plaza in December of 2000. 

NIGC FI Pate Ober observed two tables in January 2001. On March 20,2001, FI 

Pate Ober observed eight blackjack tables were in operation. 

Carlo Employee Rooks managed blackjack at Travel Plaza. He also set up the 

blackjack paperwork at Travel Plaza. He created forms for the cage and for the 

transfer of chips. He also created cash disbursement and cash receipt vouchers. 

Garrett Sliger was a blackjack pit boss at Travel Plaza. When Sliger left, Kirk 

Brumbaugh took his place. Both Sliger and Brumbaugh took direction fiom Ong. 

Both Sliger and Brumbaugh were on the Tribe's payroll, but were brought in by 

Ong. Garret Sliger is Ong's brother-in-law. 

During a January 8,2002, site visit, Sliger told NIGC FI Pate Obler that "Carlo 

runs the card games." 

Carlo provided money to establish the blackjack bank and guaranteed the 

blackjack bankroll. If the player's pool went in the negative, On,g would 

replenish it. 

The first blackjack tables were established at Rivermist in Janusuy 2001. 

Alam informed SNDA Employee Yargee that he was to "get done whatever Ivy 

Ong wanted done". 

A1 Brannon, a Carlo employee (Carlo Employee Brannon) was in charge of 

blackjack at Rivermist. 

At Rivermist, the blackjack drops and counts were done by people brought in by 

Carlo through Carlo Employee Brannon. 
43. Bob Dias, a Carlo employee, wrote policies and procedures for blackjack 

accounting. 

44. During Carlo's management of the blackjack operation, there were no internal 

control standards in place for blackjack. 

45. The SNDA took over blackjack operations from Carlo on August 28,2002, and at 

that time began to establish internal control standards. 

Blacki ack Record Keeping 

Carlo maintained supporting documentation for blackjack and was responsible for 

reporting of blackjack revenue to the SNDA. Independent audit firms hired by 

the SNDA to audit its gaming operations were unable to verify blackjack 

information due to a lack of documentation. 

In a September 5,2002, letter to Alam, the audit firm Dennis & Company 

recommended to the SNDA that that the blackjack reporting could be 

strengthened by having SNDA do it instead of Carlo, and by keeping all 

supporting documentation with the daily reports. Dennis & Company noted that 

Carlo had not provided any support for the numbers. 

In a February 27,2003 Independent Auditor's Report, the independent auditor 

stated that because of a lack of supporting documentation for blackjack revenue, 

the auditor was unable to form an opinion regarding the revenue shown in the 

SNDA income statement. 

In the Independent Auditor's Report on the Internal Control Policies and 

Procedures for Gaming Revenue Based on the Audit of the Financial Statements 

for fiscal year ended September 30,2002, the independent auditor noted that: 

A. chip inventory forms were not available for blackjack for 

game dates prior to August 28,2002; 

B. blackjack was not audited by SNDA personnel prior to 

August 28,2002; and 

C. openinglclosing table inventory forms were not available 

for game dates prior to August 28,2002. 

In a Fraud Risk Internal Control Memo attached to the Independent Auditor's 

Report for fiscal year ended September 30,2002, it is noted that [Carlo was 

responsible for blackjack operations until August 28,2002 and that no 

documentation exists to support the payment received by SNDA for blackjack 

during the audit period. 
Onn and Carlo Controlled the Blackiack Cane and Blackiack Count Room and 

Conducted the Blackiack Count 

Surveillance and Securitv 

During both SNDA Employee Yargee and SNDA Employee Haney's tenure at 

Travel Plaza the blackjack counts were done by Ong or Carlo employees. On one 

or two occasions, when there was one count room for blackjack and machines, 

Alam cleared the count room of people so Ong could conduct the count. 

During February and March of 2001, Ong and his employees began taking the 

blackjack chips fiom the drops to a room in the Travel Plaza that had previously 

been the trucker's lounge, also known as the "red room." There *were two 

blackjack tables there at the time. Ong counted the money on one of these tables. 

Later, the red room was converted to the blackjack count room. 

Blackjack drops and counts at kvermist were done by people brought in by Carlo 

Employee Brannon. 

On occasion, Ong took large bills from the blackjack table count and gave them to 

the blackjack cage cashier to increase the blackjack bank. During one of the 

blackjack tournaments, Carlo Employee Sliger brought the drop money into an 

office and Ong counted the money on the desk. 

There was a separate cage for blackjack at Travel Plaza. Check cashing took 

place in this cage directly behind the blackjack pit. 

SNDA Employee Haney was not allowed in the surveillance room. Carlo 

Employee Rooks was in the surveillance room on a regular basis. The Chief of 

Surveillance, Buddy Harjo, was Carlo Employee Rooks' father-in-law. 

On one occasion SNDA Employee Haney saw Carlo Employee Rooks leave the 

surveillance room with videopes. 

SNDA Employee Haney was never allowed to watch surveillance tapes. 

At Ong's request, Ron Hill of H & H Alarm Company drew up a proposal to 

install a matrix surveillance system at Travel Plaza, Rivermist, and Seminole 

Nation Bingo. Carlo paid for the equipment and installation of surveillance 

systems at these three locations. 

Because blackjack was operated separately, the Tribe's surveillance force was not 

asked to monitor the blackjack area. Security did not observe fills, payoffs or the 

drop. 
OndCarlo Made Hiring Decisions 

61. Ong hired blackjack employees. Dena Brady, Human Resources Director of the 

SNDA Personnel Department (SNDA Employee Brady), recruited, screened, and 

hired SNDA employees, includmg non-blackjack SNDA employees of the tribal 

gaming operations. SNDA Employee Brady was not involved in the hiring of 

blackjack employees. On occasion, her office would learn of a new blackjack 

employee when the employee submitted his or her timesheet. Otig or Carlo 

Employee Rooks brought people over to the Personnel Department and advised 

SNDA Employee Brady that they were now worlung at Rivermist or Travel Plaza. 

62. Alam told SNDA Employee Brady not to question Ong or Rook's decision to hire 

anyone. Sometimes personnel paperwork went directly to Alam, bypassing 

SNDA Employee Brady. Personnel policies were regularly violated. 

63. While many of the blackjack employees appeared on the payroll of the SNDA, 

Carlo reimbursed the SNDA for a percentage of the payroll costs of those 

employees. 

Oversight of Casino Emplovees 

64. Ong gave instructions to the on-site pit bosses and supervisors at the Travel Plaza. 

65. Ong gave directions to the casino maintenance crew at Travel Plaza. 

66. The blackjack pit bosses, who reported to Ong, scheduled the working hours of 

blackjack employees. 

67. Carlo Employee Brannon, brought in by Ong, was in charge of blackjack at 

Rivermist and disciplined employees for violation of card dealing procedures. 

68. The SNDA issued identification badges for Carlo employees. 

69. Johnny Hy was an individual brought in by Ong sometime in the fall of 2001. His 

role was liaison between the casino and the Asian community, and he acted as a 

host at the Travel Plaza. Ong reimbursed the Tribe for part of Hy's salary. Hy 

also played blackjack at the Travel Plaza. 

Approval of Credit (Markers) and Check Cashing 

70. Ong approved credit for the play of blackjack. Credit was given to players at the 

blackjack tables. Paperwork supporting the giving of credit was put in a box at 

the pit podium. Some players, including Johnny Hy, filled out their own credit 

paperwork that was then put in the box. 
The SNDA internal auditor noted on a MICS audit checklist that the SNDA did 

not issue credit for gambling. 

Ong guaranteed any checks that were cashed at Travel Plaza. 

Ong accepted checks in exchange for blackjack chips. Some checks were taken at 

the tables, but the majority was taken at the cashier cage. There was a separate 

cash cage for blackjack. Some checks were written out to Seminole Casino and 

some directly to Carlo. Carlo Employee Sliger brought the checks to Carlo's 

office at 220 Main Street, Seminole, OK and they were then deposited into an 

account in Carlo's name. 

Loans to and From Casino 

74. On more than one occasion, Ong was observed at Travel Plaza taking money fiom 

his pocket and giving it to the blackjack cage clerk when the cage was running low 

on money. A disbursement voucher was written to sayhow much money the cage 

owed Ong. 

75. Carlo requested and received several draws or loans from the SNDA to conduct 

blackjack tournaments and to increase the blackjack player's pool. 

Tournaments and Promotions 

76. Ong and Carlo Employee Rooks determined when blackjack tournaments would 

run. Ong was involved in decision-making regarding promotions, giveaways and 

grand prizes. He had direct involvement in how the tournament was run and the 

number of people who could qualify. 

77. During at least one tournament, Ong counted the drop money on the desk of his 

office. 

78. Carlo bankrolled a $100,000 prize for a tournament. 

Casino Marketing, Advertising and Esui~ment Purchasing 

79. Carlo placed radio advertisements and created newspaper advertisements for 

Rivermist and Travel Plaza, ordered advertising supplies for these operations, and 

handed out complementary items at the both locations. 

80. Carlo paid 40% of the cost of casino advertising for Rzvermist and Travel Plaza 

8 1. Carlo purchased game equipment for Rivermist and Travel Plaza. 
Proprietarv Interest in Tribe's Gaming Operations 

The same evidence that supports a violation for managing without an approved 

management contract also supports a violation of the sole proprietary interest 

provision of the IGRA. Therefore, in support of the sole proprietary interest 

violation, the Chairman reasserts paragraphs 1 through 8 1, above. 

The agency record contains documentation which sets forth the Tribe's reported 

gaming revenue for fiscal years 2001 and 2002 (October l-September 30). 

An article in the February 23,2003, edition of the Daily Oklahoman quotes Ong 

as saying he "made $1 8 million in the past three years off the Seminole's 

casinos." 

To correct these violations: 

There is no cure for these violations because the Tribe has already severed its 

relationship with Carlolong. 

Ap~eal. Within thirty (30) days after service of this NOV, Respondents may 

appeal to the full Commission under 25 C.F.R. Part 577 by submitting a notice of 

appeal and, if desired, request for hearing to the National Indian Gaming 

Commission, 1441 L Street, NW, Ninth Floor, Washington, DC 20005. 

Respondents have the right to assistance of counsel in such an appeal. A notice of 

appeal must reference this NOV. Within ten (10) days after filing a notice of 

appeal, Respondents must file with the Commission supplemental statements that 

state with particularity the relief desired and the grounds therefore and that 

include, when available, supporting evidence in the form of affidavits. If 

Respondents wish to present oral testimony or witnesses at the hearing, 

Respondents must include a request to do so with each supplemental statement. 

The request to present oral testimony or witnesses must specify the names of 

proposed witnesses and the general nature of their expected testimony, whether a 

closed hearing is requested and why. Respondents may waive their right to an 

oral hearing and instead elect to have the matter determined by the Commission 

solely on the basis of written submissions. 

Fine--Submission of Information. 

The violation cited above may result in the assessment of a civil fine against 

Respondents in an amount not to exceed $25,000 per violation per day. Under 

25 C.F.R. 575.5(a), Respondents may submit written information about the 

violation to the Chairman within fifteen (15) days after service of this NOV (or 

such longer period as the Chairman may grant for good cause). The Chairman 

shall consider any information submitted in determining. the facts surrounding: 
the violation and the amount of the civil fine, if any. 

Dated this / day of May, 2007 

Philip N. Hogen 

Chairman 

National Indian Gaming Commission