APR 2 9 1994 

Raul Garza, Chairman . Kickapoo Traditional Tribe of Texas 

Tribal Office 

P.O. Box 972 

Eagle Pass, Texas 78853 

Dear Chairman Garza: 

This letter responds to your request to review and approve the 

tribal gaming ordinance adopted by the Kickapoo Traditional Tribe 

of Texas (the Tribe) on April 13, 1994. This letter constitutes 

such approval under the Indian Gaming ~ehlatory Act (IGRA). 

Under the IGRA and the regulations of the National Indian ~aming 

 om mission (NIGC), the chairman is directed to review ordinances 

with respect to the requirements of the IGRA and the implementing 

regulations. Thus, the scope of the Chairmanls review and 

approval is limited to the requirements of the IGRA and the NIGC 

regulations. Provisions other than those required under the IGRA 

or the NIGC regulations that may be included in a tribal 

ordinance are not subject to review and approval. Also, such 

approval does not constitute approval of specific games. 

It is important to note that the gaming ordinance is approved for 

gaming only on Indian lands as defined in the IGRA. 

With the Chairmanls approval of the Tribe's gaming ordinance, the 

~ribe is now required to conduct background investigations on its 

key employees and primary management officials. The NIGC expects 

to receive asompleted application for each key employee and 

primary management official pursuant to 25 C.F.R. S 556.5(a) and 

an investigative report on each background investigation before 

issuing a license to a key employee or primary management 

official pursuant to 25 C.F.R. S 556.5(br. 

Thank you for submitting the ordinance of the ~ickapoo 

Traditional Tribe of Texas for review and approval. The NIGC 

staff and I look forward to working with you and the ~ribe in 

implementing the IGRA. 

Sincerely yours, 

Anthony J. Nope 

Anthony J. Hope 

chairman 

cc: Sandy Hansen, ~ribal Attorney - -- 

- 1850 M STREET Y W SUITE 253 WASHl\GTCIU CC 20336 -EL 202 632 7003 FAX 202 632-7066 
TRADITIONAL COUNCIL 

CHAIRMAN 

Raul Cam, MaJcateonenodua 

Traditional Tribe of Texas 

Tribal W~ce 

P.O. Box 972 

Eagk Pass, Texas 78853 

(210) 773-2105 

(210) 773-2303 

(210) 757-9228 FAX 

SECRETARY 

Pancho-Salazar, Kotachimaa 

TREASURER 

Stella V. Cana, Sacuacuia 

MEMBERS 

Jose Hernandez., Aweakodita 

Herminia Cam, Enemicua 

Resolution No. KTTT 94- 008 

ADOPTING AND ENACTING A REVISED ORDINANCE TO AUTHORIZE AND 

REGULATE THE CONDUCT OF CLASS I1 AND CLASS I11 GAMING ON 

TRIBAL LANDS 

WHEREAS, in January 1994 the Traditional Council enacted a 

resolution enacting an Ordinance Authorizing and 

Regulating the Conduct of Class I1 and Class I11 Gaming 

on Tribal Lands; and 

WHEREAS, that Ordinance was submitted to. the National Indian 

Gaming Commission for review and comment; and 

WHEREAS, the National Indian Gaming Commission has noted certain 

deficiencies in the Ordinance that the Traditional 

Council wishes to correct; and 

WHEREAS, the Tribe1 s legal counsel has prepared amendments to the 

Ordinance addressing the concerns raised by the National 

Indian Gaming Commission; and 

WHEREAS, the Traditional Council has reviewed'and concurs in the 

amendments prepared by the Tribe's legal counsel and in 

the Revised Ordinance Authorizing and Regulating the 

Conduct of Class I1 and Class I11 Gaming on Tribal Lands; 

and 

WHEREAS, the Traditional Council is the governing body of the 

Kickapoo Traditional Tribe of Texas; and 

"A Federal And State Recognized Sovereign Indian Nation" 

ma3a 
WHEREAS, the Traditional Council is expressly authorized to enact 

ordinances for the protection of the public health, 

safety and welfare; and 

WHEREAS, the Traditional Council deems it in the best interest of 

the Kickapoo Traditional Tribe of Texas to authorize and 

regulate the conduct of Class I1 and Class I11 gaming on 

tribal lands : 

NOW THEREFORE THE TRADITIONAL COUNCIL OF THE KICKAPOO TRADITIONAL 

TRIBE OF TEXAS hereby enacts the Revised Ordinance Authorizing and 

I1 and Class I11 Gaming on Tribal 

Pancho ~alazar, Secretary 

ia Garza, ~kmber 

& e He andez, Member 

CERTIFICATION 

I hereby certify that the foregoing Resolution Amending and 

Enacting the Revised Ordinance Authorizing and Regulating the 

Conduct of Class I1 and Class I11 Gaming on Tribal Lands was 

enacted by the Traditional Council of the Kickapoo Traditional 

Tribe of Texas at a duly called meeting held at the Kickapoo 

Village Indian Reservation on the 13*day of April, 1994, at which 

a quorum was present and the vote was 5 in favor, (3 against, 

and 0 abstaining. 

J~&T& 

Pancho Salazar 
REVISED ORDINANCE AUTHORIZING AND REGULATING 

THE CONDUCT OF CLASS I1 AND CLASS I11 GAMING 

ON TRIBAL LANDS 

I. PURPOSE 

The Traditional Council of the Kickapoo Traditional Tribe of 

Texas, empowered by Article VII, Paragraph j of the Constitution of 

the Kickapoo Traditional Tribe of Texas to enact ordinances and 

resolutions in order to safeguard the peace, safety, welfare and 

political integrity of the Tribe, hereby enacts this Ordinance in 

order to authorize and regulate the conduct of Class I1 and Class 

I11 Gaming on tribal lands. 

11. DEFINITIONS 

As used in this Ordinance, the following terms shall have the 

respective meanings ascribed thereto unless the context clearly 

indicates otherwise. 

2.1 "The ActM shall mean the Indian Gaming Regulatory Act, 

Pub. L. No. 100-497, codified at 25 U.S.C. Sections 2701- 

2721. 

2.2 Itclass I Gamingn shall have the meaning as set forth in 

the Act. 

2.3 "Class I1 Gaming" shall have the meaning as set forth in 

the Act 

2.4 I1Class I11 Gaming" shall have the meaning as set forth in 

the Act. 

2.5 ltCommissionn shall mean the National Indian Gaming 

Commission. 

2.6 nCompactg8 shall mean an agreement between the Tribe and 

the State of Texas or other appropriate governmental body 

authorizing and regulating the conduct of Class I11 

gaming, which Compact has been approved by the Secretary 

of the Interior pursuant to the Act. 

2.7 "Certified Public Accountantv8 shall mean a certified 

public accountant who is a member of an accounting firm 

of regional or national recognition, which firm has no 

existing or previous relationship with any management 

company with which the Tribe may contract for the conduct 

of Class I1 and/or Class I11 gaming. 

2.8 "Gamingw shall mean the playing of Class I1 and/or Class 
on tribal lands by the Compact, the Act and other 

applicable federal or tribal laws. 

2.9 IuGaming Facilityuu or "Facilitytt shall mean the 

improvements constructed on tribal lands and the 

surrounding grounds on the Property at which Class I1 

and/or Class I11 games of chance are conducted, and 

includes any parking areas and drives used for ingress 

and egress to and connecting the uuFacilityul to city, 

county or state roads and highways. 

2.10 "Gaming Operationw shall mean that economic activity 

owned by the Tribe which operates the games, receives the 

revenues, issues the prizes and pays the expenses 

associated with Class I1 and/or Class I11 gaming. 

"Gaming supply contractw shall mean any agreement between 

the Gaming Operation and any person or entity for the 

provision of goods or services to the Gaming Operation in 

an amount that exceeds $25,000 in any year. The term 

shall include multiple agreements between the Gaming 

Operation and any person or entity owned in whole or in 

part by another person or entity with which the Gaming 

Operation has another agreement for goods or services, 

when the aggregate amount of the agreements exceed 

$25,000 in any year. 

2.12 IuKey Employeev1 shall mean (1) any person who performs one 

or more of the following functions: 

(a) bingo caller, 

(b) counting room supervisor; 

(c) chief of security; 

(d) custodian of gaming supplies or cash; 

(e) floor manager; 

(f) pit boss; 

(g) dealer; 

(h) croupier; 

(i) approver of credit; or 

(j) custodian of gambling devices, including persons 

with access to cash and accounting records with 

such devices; and 
(k) if not otherwise included, (2) any person whose 

total cash compensation is in excess of $50,000 per 

year; or (3) the four highest-compensated employees 

in the Gaming Operation; and 

(1) any employee or agent of the Gaming Operation that 

is designated in the Compact as a key employee. 

2.13 "Ordinancet1 shall mean this Ordinance authorizing and 

regulating the conduct of Class I1 and Class I11 Gaming 

on tribal lands. 

2.14 !!Primary Management Of ficialw shall mean any person 

having management responsibility for a management 

contract; any person who has authority to hire and fire 

employees or to set up working policy for the Gaming 

Operation; the chief financial officer or other person 

who has financial management responsibility for the 

Gaming Operation; and any employee or agent of the Gaming 

Operation that is designated in the Compact as a primary 

management official. 

2.15 "State" shall mean the State of Texas and its political 

subdivisions. 

2.16 I1Traditional C~uncil~~ shall mean the governing body of 

the Tribe, elected pursuant to Art. V, Section 1 of the 

Constitution of the Kickapoo Traditional Tribe of Texas. 

2.17 "Tribal Landu or "tribal lands1! shall mean (1) all land 

within the limits of the existing Kickapoo Village Indian 

Reservation; and (2) any real property that is now held 

or which is hereafter acquired by the United States in 

trust for the Kickapoo Traditional Tribe of Texas and 

over whidh the Tribe and United States, as opposed to the 

State of Texas, exercise governmental power; and (3) any 

land hereafter acquired by the Tribe and held subject to 

restriction by the United States against alienation and 

on which Gaming is permitted by law. 

2.18 "TribeN shall mean the Kickapoo Traditional Tribe of 

Texas. Whenever the Tribe is accorded a right or 

responsibility under the terms of this Agreement, that 

right or responsibility shall be exercised by the 

Traditional Council or its authorized representative. 

111. GAMING AUTHORIZED 

By this ordinance, the Traditional Council hereby authorizes 

the conduct of Class I1 and Class I11 Gaming, as those terms are 

defined by the Act, on tribal lands provided that the Traditional 

Council shall not license any person to, and no person may, conduct 
Class I11 Gaming on tribal lands until the Secretary of the 

Interior has approved the Compact and has authorized the Tribe to 

engage in Class I11 Gaming on tribal lands. 

IV. OWNERSHIP OF GAMING 

The Tribe shall have the sole proprietary interest in and 

responsibility for the conduct of any Gaming Operation authorized 

by this Ordinance. 

V. USE OF GAMING REVENUES 

5.1 The Tribe's share of net revenues from Class I1 and/or 

Class I11 Gaming shall be used only for the following 

purposes : 

5.1.1 to fund tribal government operations and 

programs ; 

5-1.2 to provide for the general welfare of the 

Tribe and its members; 

5.1.3 to promote tribal economic development; 

5.1.4 to help fund operations of local government 

agencies; and 

5-1.5 to donate to charitable organizations. 

5.2 If the Traditional Council or the Tribe should elect, in 

the future, to make per capita payments to tribal 

members, the Traditional Council shall authorize such 

payments only upon approval of a plan submitted to the 

Secretary of the Interior pursuant to 25 U.S.C. S 

2710(b) (3). 

VI. AUDIT 

6.1 The Tribe shall cause to be conducted annually by a 

Certified Public Accountant an independent audit of the 

Gaming Operation and shall submit the resulting audit 

reports to the Commission. 

6.2 All gaming supply contracts that result in the purchase 

of supplies, services or concessions in excess of $25,000 

annually, except contracts for professional legal and 

accounting services, shall be specifically included 

within the scope of the audit described in Section 6.1, 

above. 
VII. PROTECTION OF THE ENVIRONMENT AND PUBLIC HEALTH AND SAFETY 

Any Class I1 and/or Class I11 Gaming Facility constructed on 

tribal lands shall be constructed, maintained and operated in a 

manner that adequately protects the environment and the public 

health and safety. 

VIII. LICENSES FOR KEY EMPLOYEES AND PRIMARY MANAGEMENT OFFICIALS 

Any person who applies for a position as a primary management 

official or key employee of any Class I1 or Class I11 Gaming 

Operation shall be requiredto complete a written application form, 

in three originals, which contains, at a minimum, the information 

listed in 25 C.F.R. Sections 556.3 and 556.4. Until such time as 

a person employed as a primary management official or key employee 

is issued a gaming license by the Traditional Council, such 

person's employment shall be temporary, l1at will," and such person 

shall be subject to immediate termination for cause or for no 

cause. 

8.1 Privacy Act Notice. The following notice shall be placed 

on the cover page of the application form that each key 

employee or primary management official must complete 

prior to being employed in any Gaming Operation. 

I1In compliance with the Privacy Act of 1974, the 

following information is provided: Solicitation of the 

information on this form is authorized by 25 U.S.C. §§ 

2701-2721. The purpose of the requested information is 

to determine the eligibility of individuals to be 

employed in a gaming operation. The information will be 

used by the National Indian Gaming Commission members and 

staff who have need for the information in the 

performance of their official duties. The information 

may be disclosed to appropriate federal, tribal, state, 

local or foreign law enforcement and regulatory agencies, 

when relevant to civil, criminal or regulatory 

investigations or prosecutions or when pursuant to a 

requirement by a tribe or the National Indian Gaming 

Commission in connection with the hiring or firing of any 

employee, the issuance or revocation of a gaming license, 

or investigations of activities while associated with a 

tribe or a gaming operation. Failure to consent to the 

disclosures indicated in this notice will result in a 

tribef s being unable to hire you in a position classified 

as a key employee or primary management official. 

The disclosure of your social security number (SSN) is 

voluntary. However, failure to supply your SSN may 

result in errors in processing your application." 
8.2 Notice Regarding False Statements. The following notice 

shall be placed on the cover page of the application form 

that each key employee or primary management official 

must complete prior to being employed in any Gaming 

Operation. 

"A false statement on any part of your application may be 

grounds for not hiring you, or for firing you after you 

begin work. Also, a false statement on any part of your 

application may result in your being punished by fine or 

imprisonment under 18 U.S.C. § 1001." 

8.3 Application Form. Each applicant for a position as a key 

employee or primary management official shall be asked to provide 

to the Tribe all of the following information: 

8.3.1 the applicant's full name, other names used 

(oral or written), social security number(s), 

birth date, place of birth, citizenship, 

gender, and all languages (spoken or written); 

8.3.2 currently, and for no less than the previous 

five years, the applicant's business and 

employment positions held, ownership 

interest(s) in those businesses, business and 

residence addresses, and driver's license 

number (s) ; 

8 3 3 the names and current addresses of no less 

than three personal references, including one 

personal reference who was acquainted with the 

applicant during each period of residence 

listed under paragraph 8.3.2 of this Section; 

8.3.4 current business and residence telephone 

numbers ; 

8.3.5 a description of any existing and previous 

business relationships that the applicant has 

had with any Indian tribe, including ownership 

interest(s) in those businesses; 

a description of any existing and previous 

business relationships that the applicant has 

had with the gaming industry, in general, 

including ownership interest(s) in those 

businesses; 

the name and address of any licensing or 

regulatory agency with which the applicant has 

filed an application for a license or permit 

related to gaming, whether or not such license 
or permit was granted; 

for each felony for which there is an ongoing 

prosecution or a conviction involving the 

applicant, the name and address of the court 

involved, and the date and disposition, if 

any; 

for each misdemeanor conviction or ongoing 

misdemeanor prosecution (excluding minor 

traffic violations) involving the applicant, 

within no less than 10 years of the date of 

the application, the name and address of the 

court involved and the date and disposition, 

if any; 

8.3.10 for each criminal charge involving the 

applicant (excluding minor traffic 

violations), whether or not there is a 

conviction, if such criminal charge is within 

not less than 10 years of the date of the 

application and is not otherwise listed 

pursuant to Sections 8.3.8 or 8.3.9, the 

criminal charge, the name and address of the 

court involved, and the date of disposition, 

if any; 

8.3.11 the name and address of any licensing or 

regulatory agency with which the applicant has 

filed an application for an occupational 

license or permit, whether or not such license 

or permit was granted; 

8.3.12 a current photograph of the applicant; 

8.3.13 any other information that the Traditional 

Council may deem relevant; and 

8.3.14 fingerprints of the applicant taken by the 

Maverick County, Texas, sheriff's department 

or Texas Department of Public Safety on 

fingerprint forms supplied by the agency which 

takes the fingerprints. 

8.4 Background Investigation. The Tribe shall conduct or 

shall cause to be conducted a detailed background 

investigation of each key employee or primary management 

official. 

8.4.1 The background investigation shall be 

conducted in a confidential manner, with the 

identity of any person interviewed in the 
course of the investigation being disclosed 

only to such officials who, in the performance 

of their official duties, have a need to know 

such information. 

8.4.2 The Tribe shall contract with the Texas 

Department of Public Safety [hereafter "DPS], 

or such other agency as the Texas Legislature 

may hereafter designate as the State agency 

responsible for conducting background 

investigations on persons involved in gaming 

pursuant to a State license, to conduct the 

background investigations on each key employee 

or primary management official of the Gaming 

Operation. At a minimum, each background 

investigation shall comply with the following 

procedures. 

8.4.2 .1 DPS shall obtain the fingerprints of 

each key employee or primary 

management official on fingerprint 

forms supplied by DPS and shall 

forward each set of fingerprints to 

the Federal Bureau of Investigation 

for processing. 

8.4.2.2 DPS shall inquire into the prior 

activities, criminal record, if any, 

and reputation, habits and 

associations of each key employee 

and primary management official. 

8.4.2.3 DPS shall interview a sufficient 

number of knowledgeable people, such 

as former employers, personal 

references, and others to whom 

referred in order to provide a basis 

for the Tribe to make a finding 

concerning the eligibility of the 

key employee or primary management 

official for employment in the 

Gaming Operation. 

8.4.2.4 DPS shall document its disposition 

of all potential problem areas and 

shall document all disqualifying, or 

potentially disqualifying, information that it obtains during the 

course of conducting each background 

investigation. 

8.4.2.5 DPS shall prepare and submit to the 
Tribe an investigative report that 

sets forth the information required 

in Section 8.6.1, below. 

The Traditional Council shall approve the 

scope of each investigation before the results 

of the investigative report are reviewed and a 

license is issued to the key employee or 

primary management official. 

Any key employee or primary management 

official of a Class I11 Gaming Operation shall 

be subject to the background investigation 

requirements and procedures specified in the 

Compact, which shall not be any less stringent 

than the background requirements and 

procedures specified in this Ordinance. 

8.5 Eligibility Determination. The Traditional Council shall 

review the investigative report on each person employed 

as a key employee or primary management official, and any 

other information deemed relevant by the Council, in 

order to make a finding concerning the eligibility of the 

person to be licensed as a key employee or primary 

management official in the Gaming Operation. 

8.5.1 No person who poses a threat to the public 

interest or to the effective regulation of 

gaming or who creates or enhances the danger 

of unsuitable, unfair, or illegal practices 

and methods and activities in the conduct of 

gaming shall be licensed as a primary 

management official or key employee. 

The Traditional Council shall have the sole 

responsibility and authority for determining 

whether a prospective primary management 

official or key employee is eligible to be 

licensed as a primary management official or 

key employee in the Gaming Operation, unless a 

Compact shall vest the State with concurrent 

authority to make that determination. 

8.6 Procedures for Forwarding Applications and Reports to the 

Commission. The Tribe shall ensure that the procedures 

set out in this Section are implemented with respect to 

each key employee and primary management official 

employed at any Class I1 or Class I11 Gaming Operation on 

tribal lands. 

8.6.1 Investigative Report. No later than 60 days 

after a key employee or primary management 
official begins employment with a Gaming 

Operation, the Traditional Council shall 

forward to the Commission the investigative 

report on such key employee and primary 

management official which was prepared by DPS 

pursuant to Section 8.4.2.5, above. Each 

investigative report shall include all of the 

following: 

8.6.1.1 steps that were taken in conducting 

the background investigation; 

8.6.1.2 the results obtained; 

8.6.1.3 the conclusions reached; and 

8.6.1.4 the bases for the conclusions 

reached. 

Eligibility Determination Report. The 

Traditional Council shall prepare and forward 

to the Commission, with the investigative 

report provided for in Section 8.6.1, above, a 

copy of the eligibility determination made 

under Section 8.5, above. 

8.7 Licensing Procedures. 

If, within 30 days after the Commission has 

received the investigative report and 

eligibility determination provided for in 

Sections 8.6.1 and 8.6.2, above, the 

Commission has notified the Tribe that it has 

no objection to the issuance of a license to 

an applicant for a key employee or primary 

management official position with the Gaming 

Operation, the Tribe may issue a license to 

such applicant. 

If, during the 30-day period provided for in 

Section 8.7.1, above, the Commission notifies 

the Tribe that it objects to the employment of 

the subject person as a primary management 

official or key employee, the Traditional 

Council shall reconsider the employment of 

said person, giving due consideration to the 

objection(s) itemized by the Commission. 

If, during the 30-day period provided for in 

Section 8.7.1, above, the Commission requests 

additional information concerning a key 

employee or a primary management official who 
is the subject of an investigative report, the 

Traditional Council shall provide or shall 

cause to be provided such information to the 

Commission. The 30-day period provided for in 

Section 8.7.1, above, shall be suspended from 

the date that the Commission requests the 

additional information until the date that the 

Commission has received the additional 

information. 

Notwithstanding any other provision of this 

Section 8.7, the Traditional Council shall 

have the sole responsibility and authority for 

determining whether a prospective key employee 

or primary management official is eligible to 

be licensed as a key employee or primary 

management official in the Gaming Operation, 

unless a Compact shall vest the State with 

concurrent authority to make that 

determination. 

8.8 Denial of License. 

8.8.1 Dismissal of Key Employee or Primary 

Management Official. Should the Traditional 

Council decide not to issue a gaming license 

to a person employed as a primary management 

official or key employee, the employment of 

said primary management official or key 

employee shall be terminated immediately. 

Notice to Commission. Should the Traditional 

Council decide not to issue a gaming license 

to a person employed as a primary management 

official or key employee, the Tribe shall so 

notify or shall cause to be so notified the 

Commission and may forward copies of its 

eligibility determination and investigative 

report (if any) to the Commission for 

inclusion in the Indian Gaming Individuals 

Records System. 

8.9 License Suspension/Revocation. If, after a primary 

management official or key employee has been issued a 

gaming license, the Tribe receives reliable information 

indicating that the employee or official is not eligible 

for employment under Section 8.5, above, the Tribe shall 

suspend such license and shall notify the licensee in 

writing by certified mail of the suspension and the 

proposed revocation. The notice shall contain the date, 

time and place at which a hearing to determine whether 

the license should be revoked will be conducted. 
8.9.1 Immediately upon receipt of the notice of 

suspension, the subject primary 

management official or key employee shall 

be suspended from all duties and 

responsibilities with respect to the 

Gaming Operation. 

8.9.2 The Traditional Council shall preside at 

a hearing at which evidence shall be 

presented and a determination made as to 

whether to revoke or reinstate the 

suspended gaming license. The decision 

of the Traditional Council shall be 

final. 

8.9.3 The Traditional Council shall notify the 

Commission, in writing by certified mail, 

of its decision to revoke or reinstate 

any gaming license that was previously 

suspended by the Council. 

8.10 Time Limitation on Employing a Key Employee or 

Primary Management Official. The Gaming Operation 

shall not retain as a key employee or primary 

management official a person who has not been 

issued a gaming license within 90 days after 

his/her initial, Itat willn employment. 

8.11 Retention of Records. The Tribe shall retain each 

application for employment as a key employee and 

primary management official and the resulting 

investigative report (if any) for no less than 

three years from the date of termination of 

employment of the subject key employee or primary 

management official. 

IX. LICENSE LOCATIONS. 

The Tribe shall require a separate license for each place, 

facility or location on tribal lands where Class I1 and/or Class 

I11 Gaming is conducted under this Ordinance. 

X. DISPUTE RESOLUTION BETWEEN THE TRIBE AND/OR MANAGER AND 

CUSTOMERS OF THE GAMING OPERATION 

10.1 Rules of Play. The rules of play for each type of 

game, along with these dispute-resolution 

procedures, shall be posted at a conspicuous place, 

visible and accessible to customers, in the Gaming 

Facility. All games shall be conducted fairly and 

honestly, pursuant to the posted rules of play. 

The posted rules of play shall govern the 
resolution of any dispute between the Tribe and/or 

Manager and any customer of the Gaming Operation. 

10.2 General Manager. Any dispute between the gaming 

public and the Gaming Operation shall be presented 

initially to the General Manager of the Gaming 

Operation. The General Manager shall strive to 

satisfy the customer. 

10.3 Manager. If the General Manager cannot resolve a 

dispute to the satisfaction of a customer, the 

General Manager shall present the dispute, in 

writing, to the Management Contractor within three 

working days. The Management Contractor shall 

attempt to resolve the dispute to the customerfs 

satisfaction. The decision of the Management 

Contractor shall be in writing, and shall be sent 

by certified mail to the customer within 10 

calendar days of the Management Contractor's 

receipt of the writing describing the dispute from 

the General Manager. The decision of the 

Management Contractor shall advise the customer 

that heishe may appeal the Management Contractor's 

decision to the Traditional Council pursuant to 

Section 10.4, below. 

10.4 Traditional Council. Any customer who is not 

satisfied with the decision of the Mangement 

Contractor (or the General Manager, if there is no 

Management Contractor) may present his/her dispute 

to the Traditional Council, in writing, no later 

than 10 days after the customer's receipt of the 

decision of the Management Contractor or General 

Manager, as appropriate. The Traditional Council 

shall review the evidence and issue a decision no 

later than 20 days following receipt of the 

customerf s appeal of the decision. The decision of 

the Traditional Council shall be in writing and 

shall be final. 

XI. NOTICE/AGENT FOR SERVICE OF PROCESS 

11.1 Any notice required to be delivered to the Tribe under 

this Ordinance or the Act shall be given to: 

Chairman, Traditional Council 

Kickapoo Traditional Tribe of Texas 

P.O. Box 972 

Eagle Pass, Texas 78853 
11.2 The Tribe's agent for service of process shall be: 

Whiteing & Thompson 

1136 Pearl Street, Suite 203 

Boulder, Colorado 80302 

Attn: Sandy Hansen 

XII. ENTIRE ORDINANCE 

This Ordinance is the entire gaming ordinance governing the 

conduct of Cass I1 and/or Class I11 gaming on the Kickapoo Village 

Indian Reservation or by the Kickapoo Traditional Tribe of Texas. 

XIII. EFFECTIVE DATE. 

13.1 Class I1 Gaming. As it relates to Class I1 Gaming, this 

Ordinance shall take effect upon its approval by the Chairman of 

the National Indian Gaming Commission. 

13.2 Class I11 Gaming. As it relates to Class I11 Gaming, 

this Ordinance shall take effect upon (i) approval of this 

Ordinance by the Chairman of the National Indian Gaming Commission 

and publication of the same in the Federal Register and (ii) 

approval of a Compact for the conduct of Class I11 Gaming by the 

Secretary of the Interior and publication of that Compact in the 

Federal Register.