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SETTLEMENT AGREEMENT 

INTRODUCTION 

This Settlement Agreement ("Agreement") is entered into and effective this 21 st 

day of July, 2004, by and between Carl Venne, Chainnan of the Crow Tribe, a federallyrecognized Indian tribe ("the Tribe") and Philip N. Hogen, the Chairman of the National 

Indian Gaming Commission ("the Chairman") relating to the matters contained in Notice 

of Violation No. NOV-04-02. 

RECITALS 

Whereas, the Tribe has conducted gaming on Indian lands at a facility in Crow 

Agency, Montana since approximately July, 2001; 

Whereas, the Chairman and the Tribe desire to resolve issues related to Notice of 

Violation No. NOV-04-02. 

Therefore, the Chairman and the Tribe have agreed to execute this Agreement and 

perform in accordance with the following covenants and conditions: 

TERMS OF SETTLEMENT 

1. This Agreement is entered into pursuant to 25 C.F.R. 5 575.6 (b) and shall be 

effective upon the signature of all parties. 
2. The Tribe agrees that it was required to submit annual audit reports of its gaming 

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operation for the 2002 and 2003 fiscal years and that it was required to submit 

quarterly statements of gross assessable revenue during 2001,2002 and 2003. 

3. The Tribe agrees that it did not submit to the NIGC audits for fiscal years 2002 

and 2003 and quarterly statements of gross assessable revenue during 2001,2002 

and 2003, as required by the Indian Gaming Regulatory Act ("IGRA") and NIGC 

regulations. 

4. The Tribe admits that the failure to submit audits and quarterly statements of 

gross assessable revenue in a timely fashion is a violation of IGRA and NIGC 

regulations. 

5. The Chairman acknowledges mitigating factors involving administrative 

difficulties the Tribe has faced in hiring and retaining qualified casino staff. 

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6. The Tribe further agrees to submit its 2002 and 2003 audits no later than October 

8,2004 and to submit its overdue quarterly statements of gross revenue no later 

than September 8,2004. 

7. The Tribe agrees to pay a fine in the amount of Ten Thousand dollars. Five 

Thousand dollars of the fine will be paid on or before September 7,2004. The 

remaining Five Thousand dollars will be suspended pending the submission of the 

2002 and 2003 audits and the overdue quarterly statements to the NIGC by 

October 8,2004 and September 8,2004, respectively. Upon successful 

submission of the aforementioned audits and quarterly statements by their 

respective due dates, the Chairman will forgive the suspended Five Thousand 

dollar fine. If the Tribe fails to submit the aforementioned audits and quarterly 
statements by such dates, they must be submitted as soon as possible and, in any 

event, no later than December 3 1,2004 and the remaining Five Thousand dollars 

of the fine will be paid on or before December 3 1,2004. 

8. The Chairman agrees upon execution of this Agreement to waive the right to 

impose any further civil fine for Notice of Violation No. NOV-04-02 against the 

Tribe, unless the Tribe fails to comply with this Agreement. If the Tribe fails to 

comply with this Agreement, the Chairman reserves the right to initiate an 

enforcement action as outlined under 25 C.F.R. 5 573.6 . 

9. The Tribe agrees upon execution of this Agreement to waive its right, if any, to 

further review of Notice of Violation No. NOV-04-02, including all rights to 

appeal to the full Commission as outlined in 25 C.F.R. 9 577 et seq. and judicial 

review pursuant to 25 U.S.C. 5 2714. 

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10. Subsequent to the parties' acceptance of this Agreement, the civil fine assessment 

set forth herein will become a Final Assessment Order of the Commission. 

ADDITIONAL COVENANTS 

1. This Agreement constitutes the entire agreement between the Chairman and the 

Tribe and supersedes all prior verbal or written agreements and understandings 

between the parties related to the subject matter hereof. No warranties, 

representations, covenants, or agreements shall be binding upon any party except 

as set forth herein. Any modification or waiver of any term of this Agreement, 

including the modification or waiver of term, must be in writing and signed by 

both parties. 
2. The Tribe stipulates that the Notice of Violation shall be deemed a final order of 

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the Commission and a final agency action pursuant to 25 C.F.R. 5 577.9(d). 

3. The Chairman and the Tribe expressly agree and acknowledge that time is of the 

essence in this Agreement. The recitals herein and above set shall be binding 

upon the parties, their agents, heirs, personal representatives, successors and 

assigns. 

4. A signature produced by facsimile shall be deememnal signature and 

shall be effective and binding for purpose 

Crow Tribe ssion 

B: 

Car enne Philip N. Hogen 

Chairman Chairman 

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