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23 Transcribed by:

24 Lauren Schechter, CCR

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1 >>CHAIRMAN CHAUDHURI: In terms of

2 the recorder, we're ready? Okay. It's 2:03. I

3 think we'll begin. First of all, before we get

4 started, we have arranged the table in as close to

5 a circle as we could make using square tables.

6 But we really want to encourage anybody, including

7 folks from NIGC if nobody else fills in any of the

8 seats to feel comfortable sitting down as part of

9 the circle at any point. We really want to have a

10 frank and open dialogue and discussion.

11 So let's jump right into it. Thank

12 you all for taking the time to be here today to

13 attend today's consultation between the NIGC and

14 tribal leadership and tribal regulatory leadership

15 as well. My name is Jonodev Chaudhuri and I'm

16 Chairman of the NIGC. And I'm honored to be a

17 part of the NIGC team who work so closely with our

18 regulatory partners. Active communication,

19 consultation and dialogue is probably the most

20 important thing we do. And I'm looking forward to

21 a very positive session today.

22 Before we move forward with

23 additional introductions, if we could have my

24 fellow Commissioner introduce himself, and then

25 we'll move into a brief blessing before full

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1 introductions.

2 >> DANIEL LITTLE: Thank you, Mr.

3 Chairman. It's nice to actually say that publicly

4 for the first time. Congratulations on your

5 confirmation. I just want to welcome everybody

6 here today. I'm very interested in hearing what

7 you all have to say. These consultations,

8 sometimes they're big and sometimes they're small.

9 But they're all important. And while this is an

10 opportunity to verbally provide comment on any of

11 the issues we're discussing, does not preclude you

12 from further submitting written comments. And I

13 think we'll discuss what the deadline is for

14 submitting any comments.

15 So I just want to welcome you all

16 here and I look forward to hearing what you have

17 to say. Thank you.

18 >> CHAIRMAN CHAUDHURI: Thank you,

19 Dan. We are in Lakota territory. And in keeping

20 with our past traditions we usually try to start

21 our consultations off with a blessing that will

22 help us engage in dialogue with open hearts and

23 open minds. We're very honored to have Mr. Brewer

24 agree to provide us with a blessing today.

25 >> MR. BREWER: First of all, I'd

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1 like to just start off by saying congratulations

2 on the appointment last week. It's good to meet a

3 lot of the NIGC people. (Inaudible).

4 Thank you for this day. Thank you

5 for bringing us together. We ask that you let us

6 all have dialogue with open hearts, and our

7 decisions will matter most to our people that's

8 going to affect (inaudible). Blessings on

9 everybody. Give them a safe trip home when this

10 meeting is over. I'm asking that you bring

11 blessings and honor to their families.

12 (Inaudible).

13 >> CHAIRMAN CHAUDHURI: Thank you,

14 Mr. Brewer.

15 So we don't have a lot of folks in

16 the room today. But I want everybody to have an

17 opportunity to speak their mind and to get their

18 comments -- any comments on the record that they

19 want to put on the record. That said, there's no

20 crime in finishing early. So if we have exhausted

21 all comments and discussion early, we will

22 probably move forward with adjourning early. But

23 that said, the most important thing is to be as

24 exhaustive as possible in terms of everybody

25 having an opportunity to present comments.

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1 So we'll move forward so we all

2 know with whom we're speaking. We'll move forward

3 with introductions. And rather than introduce all

4 the members of our team at once, we'll just go in

5 a circle and kind of -- even though we're in

6 Lakota territory, we're going to go in the

7 direction of the creeks. We'll first start with

8 our acting chief of staff, Christinia Thomas and

9 we'll go from there. But we always try to

10 recognize former NIGC alumni, and we have Mr.

11 Many-Wound sitting in the corner. Thank you for

12 your previous service to the Commission, and we

13 recognize you're continuing to do good work on

14 behalf of Indian country. With that, Ms. Thomas.

15 >> CHRISTINIA THOMAS: Thank you,

16 Mr. Chairman. My name is Christinia Thomas. I am

17 the acting chief of staff of the National Indian

18 Gaming Commission. I'm also a tribal member of

19 the (inaudible).

20 >> MILES JANSEN: My name is Miles

21 Jansen. I'm a staff attorney with the office of

22 general counsel. I'm a tribal member and tribal

23 member of the (inaudible) Indian tribes of Alaska,

24 descendant Cheyenne, Arapahoe and Oklahoma.

25 >> TOM BOLBON: My name is Tom

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1 Bolbon. I'm St. Paul region auditor with the NIGC

2 based at the Rapid City satellite office.

3 >> TROY LUNDERMAN: My name is Troy

4 Lunderman. I'm a general manager with Rosewood

5 Economic Development Corporation and member of

6 (inaudible) tribe.

7 >> Good afternoon. My name is Bill

8 (inaudible) general manager for the (inaudible)

9 casino (inaudible). I think somebody went there

10 yesterday. I'm also a world member of the

11 (inaudible) tribe. I just came here as an

12 innocent bystander to observe. (Inaudible) answer

13 a lot of my questions. But unfortunately none of

14 our elected officials are here. I was hoping they

15 would be here. It would be nice to hear things

16 that went on in NIGC but I might come up with

17 something in my mind before the afternoon is over.

18 Thank you.

19 >> KEN MANY-WOUNDS: Good

20 afternoon, Chairman, distinguished NIGC personnel.

21 I know a lot of you. Some of you I don't know,

22 and it's the first time. Thank you for giving us

23 this opportunity. My name is Ken Many-Wounds.

24 I'm from the standing rock nation of North and

25 South Dakota.

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1 >> WILLIAM BURR: William Burr,

2 (inaudible) tribe. Acting in capacity of

3 Executive Director of Indian gaming at the tribal

4 level.

5 >> JENNIFER LAWSON: Jennifer

6 Lawson. I'm a staff attorney with the office of

7 general counsel.

8 >> LINDA DURBIN: Linda Durbin,

9 regional Director St. Paul.

10 >> SHAWNA ELLIS: Shawna Ellis,

11 compliance officer out of St. Paul.

12 >> Robert (inaudible) compliance

13 officer, St. Paul.

14 >> KEN BUCK: Ken Buck, compliance

15 officer, St. Paul.

16 >> JIM MCKEE: Jim McKee,

17 compliance officer in the Rapid City satellite

18 office of the St. Paul region.

19 >> MICHAEL HONIG: My name is

20 Michael Honig. I'm associate general counsel at

21 the NIGC.

22 >> ERIC SHEPARD: My name is Eric

23 Shepard. I'm the acting general counsel at the

24 NIGC.

25 >> DEFOYLE FALL: I'm deDoyle Fall.

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1 I'm the officer in the Rapid City satellite office

2 of the St. Paul region.

3 >> CHAIRMAN CHAUDHURI: As I

4 mentioned, I'm Muskogee Creek. I'm very honored

5 to be here in the Lakota territory. And we have

6 public affairs well represented. Sarah.

7 >> Sarah Crawford, assisting. I'm

8 out in the DC office.

9 >> CHAIRMAN CHAUDHURI: It's always

10 nice to have home town person -- a new home town

11 person on our team. We already have several. I

12 also want to say thank you to our incredible team

13 at the region. Linda Durbin is our regional

14 Director as she mentioned. But her team put this

15 consultation together and on top of that has been

16 running an excellent training over the last

17 several days. Training being a fundamental part

18 of our emphasis on collaboration and coordination

19 with tribes and tribal regulators. Many thanks to

20 Ms. Durbin and everybody from the regional office

21 here.

22 So I believe Mr. Little has some

23 comments to provide us regarding -- yes?

24 >> KEN MANY-WOUNDS: If I may, Mr.

25 Chairman. Prior consultations that I've ever been

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1 involved in, is there going to be a record of this

2 meeting in some way, shape or form? Can you

3 please describe how that record is going to be

4 adhered to?

5 >> CHAIRMAN CHAUDHURI: Thank you,

6 Mr. Many-Wounds. With that I believe Commissioner

7 Little is going to move forward with a general

8 discussion about consultation and provide us some

9 additional background regarding some housekeeping

10 matters. That portion of Mr. Little's discussion

11 may answer some of your questions. Thank you.

12 >> DANIEL LITTLE: Today we're

13 going to be consulting in the manner that we have

14 over the last five years, at least since I've been

15 on the Commission. In accordance with executive

16 order 13175. A lot of you may know me. I worked

17 in Indian gaming for about 15 years now. One

18 thing that I observed prior to joining the

19 Commission was a lot of the tribal leaders were

20 frustrated that a lot of the decisions they felt

21 being made by the Commission were being made

22 without their involvement. While the Commission

23 consultation was more individualized and there

24 wasn't a lot of opportunity for input. So when I

25 came on the Commission and working with at the

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1 time Vice Chairman (inaudible) and they decided to

2 change the consultation. We're going to do more

3 inclusive and more involvement. And in accordance

4 with executive order 13175, we decided to do this

5 group type of consultation. And for the most part

6 it's worked out very well. And the purpose of

7 this is we've got an agenda of items that we want

8 to talk about today.

9 This is our opportunity to come and

10 talk to you, listen to your comments, hear your

11 thoughts, or hear your comments, but this doesn't

12 mean this is the end of the discussion. Like the

13 gentleman from Pine Ridge had stated, many of you

14 may not be able to present comments today. And

15 this is an opportunity for you to observe. And

16 that's fine. Perhaps you can take the information

17 you learn and go back to your tribal leadership

18 and put together your thoughts and submit formal

19 written comments to the Commission. That we

20 strongly encourage and I ask you to do so.

21 There will be follow-up

22 consultations on a number of these issues. A

23 couple we have consulted on before. The whole

24 purpose of that is that we are talking to you

25 first before we put pen to paper. That's what I

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1 learned growing up in this industry

2 professionally. This is what the tribes have told

3 us they want. And this is what we've been doing

4 over the last five years. I'm a big supporter

5 because I think it's been very successful. And

6 during the reg review process that we went

7 through, we updated a large number of regulations.

8 We utilized discussion drafts. That worked out

9 very well. It was an opportunity to provide our

10 thoughts, great comments from the tribes so that

11 when we entered the formal rulemaking process it

12 went very smooth. You had tribes that had a lot

13 of opportunity to be involved in the process,

14 submit comments, and affect the outcome that the

15 Commission ultimately adopted.

16 So we're going to continue that

17 consultation process throughout this discussion

18 today.

19 Let's see. As the Chairman said,

20 we're going to be here from 2 to 4 today. But if

21 there's no other comments we will end early. This

22 is an official government to government

23 consultation between the national Indian gaming

24 Commission, tribal leaders and their

25 representatives. It's not open to the public and

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1 it's not open to members of the media. So if

2 there's anyone in the room that are in those

3 groups, we ask you to please kindly excuse

4 yourself from the room.

5 There will be additional

6 consultations. April 30th in Oklahoma and May

7 20th at the Great Plains Indian Gaming meeting at

8 Shakopee. Feel free to attend either of those.

9 We're open-ended on the comments

10 but I think we are going to settle on an end date

11 for your comments. That will be published, I

12 assume, fairly soon. So look on our website at

13 www.NIGC.gov for more information. So other than

14 that, that's all I really need to add. I'll turn

15 it back over to the Chairman so we can start going

16 over the agenda items.

17 >> CHAIRMAN CHAUDHURI: Thank you,

18 Commissioner Little. I believe you touched on

19 this, but to answer your specific question, Mr.

20 Many-Wounds, yes, the consultation today is being

21 recorded. And I believe will be transcribed in

22 short order. And that's standard practice for our

23 consultations.

24 So with that, we're here today to

25 receive input and engage in dialogue on four

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1 specific areas of consultation. With us we have

2 representatives -- our general counsel's office

3 headed up by our acting general counsel as well as

4 representatives from our chief of staff's side of

5 the agency represented by our acting chief of

6 staff. In terms of process, we're going to go

7 through -- since there are only a few of us here

8 today, we're going to go through each of the four

9 topics one by one. So we'll have multiple

10 opportunities to provide input. But we'll provide

11 that input and engage in that dialogue one topic

12 at a time.

13 So to start us off, we have our

14 general counsel's office here to provide an

15 overview in conjunction with the chief of staff's

16 office regarding those four topics. At this point

17 I'll turn it over to Mr. Shepard.

18 >> ERIC SHEPARD: Thank you. I'm

19 just really going to turn it over to associate

20 general counsel Michael Honig who is going to talk

21 about this topic which is the privacy act, so that

22 no one has to hear me speak the whole time.

23 >> Michael Honig: We'll do the

24 most exciting one first, which is the privacy act.

25 The NIGC is proposing to make several revisions to

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1 our privacy act regulations. We want to make

2 clear at the outset this doesn't make any

3 requirements or changes on tribes and how they

4 collect, process any information. This is all

5 NIGC's internal processes. The proposed

6 regulations govern the submission requirements for

7 requests that we receive from the public, and then

8 how we process and respond to those requests. It

9 really will have negligible if any impact on

10 tribes.

11 So we've not updated the privacy

12 act regulations since 1992. So they're out of

13 date, and they need to be fixed. With these

14 proposed changes we hope to eliminate old and

15 burdensome procedures and incorporate better

16 practices we've learned over the years to increase

17 the efficiency of our internal processes. I'm not

18 going to list every single change we're making.

19 I'm just going to kind of hit the broad strokes.

20 But changes include consolidation of procedures

21 governing how an individual may request access to

22 information from the agency; the creation of

23 policies for how the NIGC will process requests in

24 conjunction with other federal agencies. We're

25 going to streamline our agency procedures to

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1 coincide with our freedom of information act

2 regulations. So right now the things like

3 deadlines are out of wack. So we're going to

4 bring everything in basically so that they work

5 better together. We're going to update the list

6 of records that are exempt from disclosure under

7 the act. The proposed regulations will also

8 create new provisions that more clearly explain

9 how the agency complies with specific aspects of

10 the privacy act. This will include procedures for

11 requesting accountings of record disclosures and

12 providing notice to individuals in cases where it

13 is required to disclose records, in cases of

14 emergency, or pursuant to a court order. So

15 that's it in the broad strokes.

16 We put the actual proposed changes

17 up on our website so you can see in more

18 specificity exactly what we're planning to do.

19 >> CHAIRMAN CHAUDHURI: Thank you,

20 Mike. So at this time we would like to move

21 forward with engaging in dialogue. Anybody that

22 has a comment regarding the privacy act topic,

23 please feel free to weigh in at this time.

24 Certainly nobody is under any obligation to

25 provide comments. But feel free. Going once.

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1 Going twice. Okay.

2 Moving forward, and again we have

3 four topics to cover -- at the end of this we'll

4 provide an additional opportunity, since there are

5 so few of us, to bring up -- to come back to any

6 of the topics that we missed. But we'll move

7 forward to the second topic on our list, which

8 involves our NEPA manual. For that we have

9 another representative of the office of general

10 counsel here, Miles Jansen who will provide us

11 some background on that.

12 >> MILES JANSEN: Thank you, Mr.

13 Chairman. NIGC is planning on adopting a NEPA

14 policies and procedures manual that will conclude

15 a categorical exclusion or CATEX for the approval

16 of management contracts. Previously the NIGC

17 determined that the approval of a management

18 contract under IGRA is a major federal action that

19 requires NEPA review. Such review takes the form

20 of an environmental assessment, or EA, or

21 environmental impact statement, EIS, both of which

22 are very costly and time consuming to tribes.

23 By adopting the CATEX, tribes would

24 not be required to prepare an EA or an EIS except

25 in the case of extraordinary circumstances. The

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1 policy and procedure manual NIGC now seeks to

2 adopt is limited in its scope. In addition to

3 setting forth the procedures, applying a CATEX, it

4 will also define extraordinary circumstances under

5 which a CATEX would not be appropriate, and also

6 the policies and procedures to be followed in

7 order to conduct a NEPA review if that would be

8 necessary.

9 By adopting the manual, the

10 Commission hopes to end the uncertainty

11 surrounding NEPA review requirements and save

12 tribes both time and money.

13 >> CHAIRMAN CHAUDHURI: Thank you,

14 Miles. We'll move forward with comments at this

15 time. But I should add because this meeting is

16 being transcribed, whenever we provide comments if

17 we could state our name and our association for

18 the record, that will help keep the transcription

19 in order.

20 >> KEN MANY-WOUNDS: Thank you, Mr.

21 Chairman. Ken Many-Wounds for the record. My

22 personal opinion or comments on this, this is long

23 overdue. This is something that's been needed.

24 With the (inaudible) tribe back in 1992, we had to

25 go through this process. And believe you me, it

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1 was a nightmare. It's a nightmare for NIGC

2 because I think you guys catch the brunt of it

3 because it's so time-consuming within your house.

4 When it gets in your hands -- so my personal

5 opinion, I don't see any tribes that would object

6 to doing something like this because it's going to

7 streamline the process. It's less headache on

8 both sides of the fence here. So I applaud the

9 Commission for looking at putting these things

10 together for a drastic change in this requirement.

11 Thank you.

12 >> CHAIRMAN CHAUDHURI: Thank you

13 so much for that comment. Any additional comments

14 on the NEPA side of these consultations?

15 Okay. With that, moving forward,

16 we'll move on to the third topic of consultation

17 which involves our proposal to provide some

18 nonmandatory guidance regarding Class 3 Minimum

19 Internal Controls. For that piece we have our

20 acting chief of staff, Christinia Thomas, to

21 provide us additional background.

22 CHRISTINIA THOMAS: Thank you, Mr.

23 Chairman. The NIGC's Class 3 Minimum Internal

24 Controls Standards, or MICS, were promulgated in

25 1999 and then revised in July of 2002.

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1 A lot has changed in the gaming

2 industry since 2002 and the MICS have not kept up

3 with those changes. Due to the Colorado River

4 Indian Tribe, or CRIT decision, the NIGC does not

5 have the authority to promulgate or update the

6 Class 3 MICS as regulations. However, we feel

7 there's still a need to have them.

8 Many tribes still rely on the MICS

9 and in some cases the MICS are part of a tribal

10 state compact or the tribes' gaming ordinances.

11 During our last regulatory review process we asked

12 for comment on how we should proceed with regard

13 to the Class 3 MICS. We received a lot of great

14 responses. Some wanted us to implement new

15 regulations, while some wanted us to withdraw the

16 regulations and do nothing.

17 We have reviewed all the comments,

18 and the Commission decided that it is time to

19 propose issuing the Class 3 MICS as guidance.

20 These will be advisory only, and unforcible by the

21 NIGC but will allow us to make sure the MICS keep

22 up with the advances in the gaming industry and

23 provide guidance to the tribes that do rely on the

24 MICS.

25 The plan is to, one, develop

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1 updated Class 3 MICS guidance; two, publish them

2 for comment; three, consider all the comments and

3 revise as necessary; and finally, publish guidance

4 and at the same time withdraw the regulation.

5 Because it will be guidance instead of regulation,

6 we'll be able to be much quicker and adapting to

7 changes in the industry.

8 >> CHAIRMAN CHAUDHURI: Thank you,

9 Ms. Thomas. So let's move forward with any

10 comments on that.

11 >> KEN MANY-WOUNDS: Thank you, Mr.

12 Chairman. Ken Many-Wounds. I hope I'm not the

13 only one that's going to monopolize the mic.

14 (Inaudible). Going back to what Christinia said,

15 1999 the Minimum Internal Controls were adopted

16 for Class 3. I don't think there's anybody in

17 this room possibly that was around in 1999. I

18 was. When it came out, they were a joke at that

19 point in time. They were ill written. They were

20 all over the map. You had to turn from page one

21 to 25 to figure out what was going on from that

22 one section, and vice versa. It was all over the

23 place. So in 2002 they were -- prior to that, the

24 first MICS advisory committee was put together

25 where tribes were then allowed to have comment and

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1 input on how to draft these Class 3 minimum

2 internal control standards other than having --

3 excuse me, I know there's a lot of attorneys in

4 here, no disrespect intended -- the attorneys who

5 wrote them didn't know what they were writing. It

6 never worked in the casino. It never worked in

7 the regulatory field. It took Nevada,

8 Mississippi, Michigan, New Jersey to throw them

9 onto a piece of paper, cut and paste here and

10 there. And when we went out to provide training

11 on these, NIGC took it in the rear end big time.

12 So it was decided real quickly we needed to redo

13 these. And over time they have been changed

14 periodically. Various administrations within NIGC

15 have tweaked these. It's a good thing, keeping up

16 with the industry standard as Christinia has

17 indicated.

18 My personal opinion on this is NIGC

19 has no authority based upon the Colorado River

20 Indian case to be involved in any way, shape or

21 form with Class 3 Minimum Internal Control

22 Standards. That's vested between the states and

23 the tribal government within that compact

24 language. It's unfortunate that some of these

25 states put those internal controls within their

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1 compacts. My opinion: Big mistake. Now they

2 have to be held accountable to them. Where other

3 tribes didn't do that, they just adopted them,

4 developed -- adopted the internal controls,

5 developed their tribal internal controls and went

6 on with this. So since 2002 when these MICS had

7 been out there and every year since that period of

8 time, the outside financial audit has been

9 conducting an AUP using the NIGC checklist that

10 have been developed in monitoring and in making

11 the tribes adhere to these Class 3 Minimum

12 Internal Controls, which in the CRIT case

13 everybody thought they were okay. NIGC had

14 authority to do that. But we know otherwise now,

15 seven, eight years after the fact.

16 Where I'm getting at is that the

17 tribes -- probably the greater majority of them,

18 and I cannot put a finger or percentage of number

19 of tribes who have followed them, developed them,

20 have had to adhere to them, where findings have

21 been identified within the outside independent

22 audits. These have been turned in on an annual

23 basis to the NIGC for their auditors to review or

24 not review or whatever happens with them. They

25 used to be reviewed -- I think they still are.

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1 But the tribes have been following

2 them. I do not see the essence of the NIGC

3 wasting the tribes' valuable fees that are paid

4 that make up the NIGC budget on manpower, man

5 hours, to devise something that is guidance or

6 guidelines only. And the reason I say that is the

7 tribes have been following their Minimum Internal

8 Controls, developed them since 2002 up until 2013,

9 leading into 2014. That's a period of 12 years.

10 They have done their due diligence. We don't need

11 NIGC writing guidance for us any longer. We have

12 sophisticated our knowledge, our ability. We've

13 defined and honed our skills to regulate Class 3

14 in conjunction with the states who do what the law

15 says they have the capability of doing. NIGC

16 should just back off based upon the CRIT case,

17 leave well enough alone, and let the tribes

18 regulate what was intended through the CRIT case

19 as well as the way IGRA is written where Class 3

20 belongs to the tribes.

21 I could go on and on, but that's

22 the gist of my comments. The tribes are

23 sophisticated enough, have the knowledge to

24 regulate their own Class 3 gaming. You've

25 designed part 543, extracting -- cut and pasting

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1 out of 542 into 543. That's a lot of that stuff

2 has come right out of 542. 542, your auditors

3 have said it, your training in the last three

4 days. They've thrown out 542. 543 goes to

5 another level on Class 2 stuff. It includes

6 gaming machines which used to have its own

7 separate checklist, separate internal controls.

8 It has now been included under the face of bing el

9 where Class 2 gaming facsimile devices represent.

10 So they're covered. And 543 is even over and

11 above in most cases 542, which I'm not going to

12 comment if it's good or bad until we get into the

13 nuts and bolts of seeing how these new system of

14 internal controls have to work hand in hand with

15 the ticks. You set up another level. In some

16 cases it's good. Some cases, my opinion, it's

17 over bearing. But it's yet to be seen how these

18 things play out. I think it's a good checks and

19 balances developing that system internal controls

20 to match the ticks or to define how those ticks

21 are to be implemented. But there's no reason to

22 waste your time, our money, in the fees that are

23 paid to write guidances when they don't hold

24 water. So thank you, Mr. Chairman.

25 >> CHAIRMAN CHAUDHURI: Thank you

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1 so much for those comments. Never feel sideways

2 about monopolizing the mic, especially when we

3 have four commenters in the room. Every comment

4 is appreciated.

5 I want to give other members of

6 NIGC an opportunity to weigh in. But let me just

7 -- because we do want this to be a dialogue, let

8 me just respond very briefly. We definitely

9 recognize not only the legal limitation that CRIT

10 provides with regard to Class 3 MICS, we

11 understand some of the policy considerations

12 you've raised regarding NIGC's appropriate rule

13 and when it comes to Class 3 MICS. So we're

14 mindful of that.

15 But the approach that I think is

16 being proposed -- try to be as clear as possible

17 that in recognizing that the CRIT decision

18 notwithstanding, and other policy decisions

19 notwithstanding, many compacts do reference the

20 MICS, and they haven't been updated for many, many

21 years. The idea is what can be done to continue

22 to be helpful within our appropriate regulatory

23 authorities to still help support tribal efforts

24 to ensure a strong regulatory structure on the

25 ground. So the perspective I think we're all

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1 coming from is doing what we can within

2 appropriate authorities to be a supportive partner

3 with that. We are very mindful of our

4 limitations, and we work very hard not to go

5 beyond that. But I tried to make the point that

6 these proposals are in keeping with those

7 considerations.

8 But I've got a question to you, Mr.

9 Many-Wounds. Given the fact that the Class 3 MICS

10 haven't been updated for many, many years, in

11 terms of efforts that tribal regulators have made

12 to work with them, have you seen any difficulties

13 that either you or your regulatory colleagues have

14 faced in terms of some of the outdated aspects of

15 what's currently on the books?

16 >> Great question Mr. Chairman. I

17 think a lot of these TGRAs with the minimums that

18 are the foundation when they have run across

19 issues such as newer technology, other things that

20 come into play, they have designed and implemented

21 written internal controls that are above and

22 beyond the foundation that's already established

23 from the original MICS, and the tweakings that

24 have gone on through the years by going out,

25 getting training, networking with other TGRAs.

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1 Again I can't say everybody has done that. But

2 the casinos or the TGRAs that want to be in

3 compliance, that have great integrity and

4 accountability of the tribal assets have taken

5 that extra step and developed written internal

6 controls that are higher standards than the MICS

7 542 stands today. That would be my response.

8 >> CHAIRMAN CHAUDHURI: Thank you.

9 Before requesting additional comments on this

10 topic, any other members of our team want to weigh

11 in at all? Okay.

12 Any additional comments on this

13 topic?

14 >> Thank you, Chairman. Bill

15 (inaudible), general manager (inaudible) tribe.

16 Kind of background on myself. I used to work for

17 Union Health Service for 28 years of my life. I

18 ran hospitals. I was the CEO for about 20 of

19 those 28 years. I was trying to make 30 years but

20 I basically got burnt out. I retired about three

21 years ago. Unfortunately I can't get any money

22 because I'm too young yet so I have to wait.

23 But I know what you're talking

24 about in terms of regulations. We're inundated

25 with many regulations in Indian health services

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1 especially Medicare services. Very difficult

2 challenges. One things about regulations and

3 rulemaking is that you always have to look at your

4 environment. Things change. I think back in 1999

5 I think when gaming first came into play, there

6 was probably a lot of unforeseen factors to

7 consider when you develop these regulations.

8 Probably back then they didn't know these things

9 were going to happen. Unfortunately they did,

10 like the Colorado River case and so forth. But I

11 always believe that whoever regulates the gaming

12 industry will always need guidance or assistance

13 of some kind. I think this week was probably the

14 most valuable thing I've participated in since

15 I've been involved in gaming for two years. One

16 as a general manager and one as a financial

17 manager at the casino. Thank you for having that

18 training.

19 Regarding Ken's comments, I do

20 agree that we really do work hard at the tribal

21 level and try to find ways to streamline our

22 policies and procedures and how to best fit our

23 organization so we can basically what, stay out of

24 trouble? Stay in compliance? I think that's the

25 name of the game, to stay out of trouble. Because

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1 we know gaming involves millions and millions of

2 dollars and we have to have strings attached. I

3 don't care how you look at it. Even those of us

4 in health care, we dealt in Medicare dollars.

5 Millions and millions of dollars, there are

6 strings attached. They're attached for some

7 reason, because you don't want criminal activity,

8 taxpayers money, I could go on and on. But I

9 understand what's being said here. But I kind of

10 like your concept of trying to have some type of

11 guidance. But again I think participation from

12 tribes in how you develop that guidance is needed

13 because everything is different. You always have

14 to look at the environments that you're serving.

15 Thank you, Chairman.

16 >> CHAIRMAN CHAUDHURI: Thank you

17 for those comments. Mr. Many-Wounds?

18 >> KEN MANY-WOUNDS: Bill raised a

19 good question. With these guidance that's being

20 proposed, will there be tribal input such as MICS

21 advisory committees, that whole gamut of setting

22 these out, having strategic meetings and

23 alignments of the various people, people selected

24 to serve on this committee, which costs money to

25 do that. That's the bottom line. Serious money.

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1 And that's what I guess my biggest -- being a

2 proponent against doing something like this.

3 What's this going to cost if they were going to go

4 down this road and it's only guidance? I'm sure

5 you can't come up with a figure right off the top

6 of your head. But it's time consuming. Is it

7 cost effective?

8 >> CHAIRMAN CHAUDHURI: I'll turn

9 it over in a second. But let me address that.

10 You had mentioned a tribal advisory committee.

11 Well, we reserve judgment regarding the most

12 effective way to do this. However, we also

13 recognize a lot of what comes with formal tribal

14 advisory committee. So additional legal

15 requirements kick in. But also you're talking

16 about money, as you mentioned, the expense

17 involved in formation and running -- I mean, and

18 continued operation of a tribal advisory

19 committee. But also time. And we recognize that

20 the time element of a tribal advisory committee

21 approach. That said, reserving kind of judgment

22 exactly in terms of what form the input will be

23 received, as Ms. Thomas already referenced, I just

24 want to echo this. It is and always has been part

25 of our game plan to engage in full scale dialogue

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1 regarding the guidance and receive as much

2 possible input from Indian country as possible.

3 So there will be comments received. There will be

4 comments received through consultations such as

5 today's consultation before we even start talking

6 about the nature of the guidance. Once the draft

7 guidance is developed, we certainly anticipate a

8 draft being circulated for additional comment.

9 That isn't necessarily the same approach as a

10 tribal advisory committee. And we think that

11 there are some benefits frankly to not going the

12 tribal advisory committee approach. Probably the

13 most important of which is no matter how -- well,

14 our main goal is to receive as many comments as

15 possible, no matter how wonderful the members of

16 the advisory committee may be on a given matter.

17 We are open to receiving comments from all tribes,

18 and all tribal regulators in the process. And so

19 that's one of the other aspects of the tribal

20 advisory committee that may suggest going a

21 different approach. But I'll turn it over to

22 Commissioner Little who is giving me the sign.

23 >> DANIEL LITTLE: Thank you, Mr.

24 Chairman. Mr. Many-Wounds, thanks for kind of

25 raising the issue earlier about the whole idea of

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1 why we're doing this, and -- I kind of look at

2 this, and it is one of the reasons we're trying to

3 gather information here, to learn here before we

4 make a decision on what we're doing. But I kind

5 of look at putting guidance out there as another

6 form of technical assistance we provide to tribes.

7 We've been such a hallmark of where we've been in

8 the last five years and what we're doing. We make

9 a lot of recommendations in the form of bulletins

10 and guidance that we put up. It's been a long

11 history of the Commission to do things of that

12 nature.

13 But as you look at what we do with

14 543, a long process, tribal advisory committee

15 that was very, very valuable. But when you look

16 at 543 and kind of where the areas of 542 -- we

17 can rely a lot on 543. We can use that as, you

18 know, a potential template for all the areas that

19 -- we don't necessarily -- we just need to pull

20 the references of 542. And then from my

21 calculations there's only three major areas --

22 gaming machines, table games, and Keno, that we'd

23 actually have to discuss that would not have

24 overlap with the 543. So I'm not really thinking

25 it's going to be a huge lift. It's going to take

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1 some time but it's not -- if we decide not to

2 utilize the tribal advisory committee, it would

3 not be the huge cost that 543 was. And when I do

4 reference huge costs, I'm not just saying the

5 costs of the Commission. I do know that tribes

6 and I want to acknowledge the fact that tribes

7 spent millions of dollars of their own money to,

8 you know, assist in the process to update 543.

9 And that's one of the reasons why I think we do

10 have a good regulation that was so successful. So

11 thank you for that comment.

12 >> CHAIRMAN CHAUDHURI: Thank you

13 for those points, Commissioner Little. I

14 definitely agree with those. Any additional

15 comments regarding this portion of the

16 consultation before moving forward?

17 Okay. With that we'll move forward

18 to our fourth and final consultation topic. One

19 which I think we're all very excited about, and

20 it's the Buy Indian goods and services regulation

21 that we are proposing. We refer to it as BIGS for

22 short. But for that we have Mr. Shepard to give

23 us some additional background on that topic.

24 >> ERIC SHEPARD: The Commission is

25 considering adopting Buy Indian goods and

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1 services, or BIGS regulations that provide a

2 preference to qualified Indian owned businesses

3 when the Commission purchases goods or services at

4 fair market price. This is in keeping with the

5 Commission's mission, and is being done as a means

6 of promoting tribal economic development and

7 tribal self-sufficiency through increased

8 employment opportunities and strong tribal

9 governments. This proposed regulation is an

10 attempt by the Commission to codify what the

11 agency is already doing to give preference as much

12 as practicable to qualified Indian owned

13 businesses when purchasing goods or services at

14 fair market prices.

15 I want to make it clear that the

16 BIGS regulations are for the Commission's own

17 procurement of goods and services only. It does

18 not mandate Indian tribes to purchase from Indian

19 owned businesses. It affects only the Commission.

20 The proposed regulations are nearly

21 identical to the Bureau of Indian Affairs Buy

22 Indian act regulations on which the BIA previously

23 held consultations. There is one key difference,

24 which is that the authority in the BIA's

25 regulations was derived from the Buy Indian act

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1 itself while the Commission's authority is derived

2 from the Indian gaming regulatory act. In the

3 future it might become necessary for the

4 Commission to seek delegated authority from the

5 Secretary of the Interior to use the Buy Indian

6 act because that act provides for higher level of

7 Indian preference. But right now the Commission

8 is proceeding solely under its authority provided

9 under IGRA.

10 >> CHAIRMAN CHAUDHURI: Thank you,

11 Mr. Shepard. In short, we're doing what we can

12 given available authority. So with that, we'll

13 move forward with comment.

14 >> Thank you, Mr. Chairman. Ken

15 Many-Wounds. I've read this. First and foremost

16 you're going to provide training once you

17 implement this? Because it's going to be a heck

18 of a time trying to figure out what rules, what

19 dollars to get somebody even possibly into the

20 system. If you provide training, I'm all for it

21 so that somebody out there has a competitive

22 advantage or not an advantage, but the same

23 competitive field out there for people, small

24 businesses who want to possibly supply goods to

25 the NIGC, they're not left in the dust. They get

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1 the same opportunity as bigger known companies out

2 there because there are some small entrepreneurial

3 ships out there that they're not going to have the

4 knowledge, the expertise. So if training was

5 provided, I don't know how you could do it, but

6 thought process suggests recommendation if it's

7 ever implemented that it's a level playing field

8 from the small to the large. That would be my

9 first comment.

10 >> ERIC SHEPARD: That's an

11 excellent point. We hadn't I think gotten quite

12 that far down the road but that is something we

13 definitely need to consider.

14 >> KEN MANY-WOUNDS: Again, Mr.

15 Chairman, I think this has been a long time

16 coming. This was discussed years and years and

17 years ago but I think your administration here is

18 the first one to actually bring it to the table

19 and put some words on the paper. I applaud the

20 effort. I would be behind it. I would support

21 it, my one individual support would lead to, but

22 if it was a level playing field where people could

23 be competitive, I would be all for it.

24 The next thing is goods and

25 services is covered everything from pens, papers,

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1 to trash cans, to staplers, to staples. Does it

2 cover the whole gamut of products used in the NIGC

3 office?

4 >> ERIC SHEPARD: Yes. We cover

5 everything, including travel, making sure that we

6 go to tribal --

7 >> Travel agencies?

8 >> ERIC SHEPARD: We're locked into

9 the federal travel agency. But preference would

10 be at staying at tribally owned properties, that

11 level of preference as well.

12 >> Okay. So if you have

13 consultation, it would be bid or awarded to a

14 possible Indian owned hotel, casino. I got you.

15 >> CHAIRMAN CHAUDHURI: We also are

16 mindful of our stewardship responsibilities for

17 travel funds. There's still fair market value

18 requirement in there so that we also maintain our

19 responsibilities with the funds we receive.

20 >> Thank you. Ken Many-Wounds

21 again. So in competitive bidding for let's say

22 hotels, it would have to be a bid that would be

23 under the GSA hotel rate so to speak to be

24 competitive? Or are you guys going to stay in

25 line with that? That's travel. But if you're

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1 going to stay at a hotel, there are GSA rates to

2 be adhered to.

3 >> ERIC SHEPARD: It wouldn't

4 require tribes to out bid us on hotel rates. The

5 GSA rates sort of are what they are. But when we

6 book hotel, if the employee has a choice between

7 staying at the holiday Inn down the road or at the

8 tribal facility, they should stay at the tribal

9 facility. And for conference locations, that

10 would probably be the bigger one we do go out to

11 bid and solicit proposals from folks, this would

12 really apply pretty strongly to that.

13 >> Can we bid on the Chairman's

14 suits?

15 >> CHAIRMAN CHAUDHURI: I'm not

16 sure what to read into that! My wife is always

17 telling me I've got to get a new wardrobe. I hope

18 you haven't been talking to her about it. I'm

19 already in enough trouble.

20 >> KEN MANY-WOUNDS: Thank you

21 again, Chairman, for the explanation. Again, I

22 would support something like this. I think the

23 tribe is long overdue. I think they would welcome

24 the opportunity to obtain some of their fees back.

25 That's my point.

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1 >> CHAIRMAN CHAUDHURI: Thank you

2 very much for those comments, Mr. Many-Wounds.

3 >> TROY LUNDERMAN: Troy Lunderman.

4 I guess with that, some of these tribes do have

5 corporations that can do all this. If you're

6 going against a private business or a mom and pop

7 shop that we have the same product, of course the

8 corporation can offer lower prices than a personal

9 business owner. How do you guys play into that?

10 Right off the top, it's really not fair, you think

11 on paper -- so what would be when you guys look at

12 that, what would decide that?

13 >> CHAIRMAN CHAUDHURI: I'm happy

14 to have others weigh in, but let me say there's

15 nothing on the books right now. That's true --

16 we're not the only agency that is in that

17 position. But we try to do what we can. Already

18 this will be another step forward in terms of

19 doing everything we can within our appropriate

20 authorities to work with folks who come from

21 Indian country, who frankly help pay our fees to

22 do what we can to continue to collaborate.

23 Now, there will always be ways for

24 vendors and tribal enterprises to not just work

25 better with us, but with other agencies who may

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1 have similar types of preference rules. But

2 ultimately we can't necessarily get into the

3 business decisions that the tribes make. We

4 definitely stay out of that way. But for the

5 folks who have fair market options available, we

6 will make an effort as an agency through our BIGS

7 rule to support Indian goods and services.

8 >> Chairman, Bill (inaudible). I'm

9 familiar with a lot of federal regulations when it

10 comes to procurement. I'm sure you're all aware

11 of FAR, Federal Acquisition Regulation. That

12 thing is a nightmare to deal with. When I was in

13 health services we basically developed a manual

14 that kind of coincided to follow the FAR to try to

15 streamline how we procure services, especially

16 when it came to big purchases like doctors,

17 nurses, and so forth with contracts. I applaud

18 the Commission, Chairman, for trying to develop

19 something to Buy Indian act. I'm not sure if you

20 have your own set of procurement manuals or

21 guidelines which you follow. I'm not sure if you

22 strictly follow the FAR but you might want to

23 consider developing something that coincided with

24 the FAR to try to streamline your processes in

25 terms of acquisitions. But I think the Buy Indian

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1 is a good starting point, so I applaud for that.

2 Thank you, Chairman.

3 >> CHAIRMAN CHAUDHURI: Thank you,

4 sir.

5 >> ERIC SHEPARD: Thank you very

6 much. That put what we're trying to do here I

7 think in better context than I did. This would

8 actually be the Commission's FAR regulations.

9 Thank you.

10 >> CHAIRMAN CHAUDHURI: Thank you

11 so much for those comments. Additional comments

12 on this topic before we move forward? Okay.

13 So I believe we've received

14 comments now -- I mean, we covered the four topics

15 of consultation. I do want to give one last

16 opportunity regarding those four topics since we

17 went in order if there are any specific comments

18 regarding one of those topics that maybe just came

19 to mind that you would like to put on record.

20 Also bearing in mind this isn't the only

21 opportunity to get comments on the record either.

22 >> TROY LUNDERMAN: Troy Lunderman.

23 I guess with the Class 3 guidance, I look at it as

24 far as tribes and money, if it's not a necessity,

25 if there's nothing that you guys can do, I don't

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1 think the tribes should be paying money for it.

2 If it is a guidance, I think maybe that's

3 something that you guys can do, wherever it's at,

4 and bring it to the tribes to look at. I think

5 just as far as fundingwise, we know what

6 conditions our tribes are in. We know what these

7 casinos do for our people. If it's not about

8 regulation, if it's basically opinion and stuff to

9 me is a waste of money. That money could be spent

10 somewhere else. That's just how I feel.

11 >> CHAIRMAN CHAUDHURI: Thank you

12 very much for that comment. Again, I'll let

13 others weigh in on this. Just in terms of the

14 context from which we're looking at the proposal,

15 even -- separate and apart from the enforcement of

16 Class 3 MICS, we do see significant benefit

17 consistent with IGRA in supporting tribal efforts

18 to support the regulatory structure of Indian

19 gaming across the board. And so we do see

20 ourselves as an active partner with tribes and

21 tribal regulators who seek to strengthen the

22 structure of their operations. So separate and

23 apart from being able to enforce the specific

24 Class 3 MICS, we see a broader responsibility that

25 we have to support Indian country regulators and

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1 tribal governments. And so from my perspective at

2 least, I see providing mandatory -- I mean,

3 nonmandatory -- nonmandatory -- decidedly

4 nonmandatory guidance as consistent with our

5 overall efforts as Commissioner Little mentioned,

6 aimed at providing appropriate training and

7 technical assistance to support the regulatory

8 structure of the industry.

9 That's the tie in, at least for me.

10 I don't want to speak for fellow Commissioner.

11 >> DANIEL LITTLE: I do definitely

12 understand your concern. I think where I keep

13 falling back on is that we do get a lot of

14 requests for technical assistance. And it's not

15 just technical assistance for Class 2. It's all

16 over. So we do a lot of Class 3 technical

17 assistance. And we do hear from tribes that they

18 do need help in these areas here. So you know,

19 it's something that -- it's voluntary. They're

20 asking for it. So we've been doing our best to

21 try to accommodate them.

22 >> CHAIRMAN CHAUDHURI: Yes, sir.

23 >> KEN MANY-WOUNDS: Thank you, Mr.

24 Chairman. Ken Many-Wounds. In lieu of what

25 associate Commissioner little has just said, then

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1 my suggestion would be that you provide this

2 technical assistance to these individual tribes on

3 a case-by-case basis without developing a full

4 blown guidance for them. Handle it on a

5 case-by-case basis so that there's not man hours,

6 an exorbitant amount of money spent on

7 development, the implementation as guidance with

8 all these things. Handle it case by case. If

9 it's requested from a tribe that needs technical

10 assistance Class 3, provide it to them. Don't

11 make us all have to -- I guess don't see it being

12 a good thing when you guys are traveling around

13 the country. I think you're going to get a lot of

14 resistance. That's just my gut feeling on this.

15 Class 3 -- Class 542 in a lot of regulators' minds

16 today doesn't exist with your 543 implementation

17 as of last year or six months ago. 542 should be

18 taken and stricken from the NIGC website as of the

19 implementation of 543. They should be

20 disappearing. They should have disappeared. They

21 don't exist in anybody's mind any longer. That's

22 just my take.

23 DAN LITTLE: Thank you.

24 >> Mr. Chairman, Bill (inaudible)

25 -- I'm relatively new to this industry, and Class

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1 3, and Class 2, and on and on. But whether or not

2 this week in terms of 543, I think that's where it

3 is, I think that needs to be (inaudible). And a

4 lot more technical assistance and training

5 provided ongoing all the time. I think 543 is

6 kind of answered a lot of my questions this week,

7 and I think it needs to continue to be looked at

8 and how we can continue to improve that particular

9 regulation within title 25. I think we need to

10 continue working in that direction with 543.

11 Thank you, Chairman.

12 >> CHAIRMAN CHAUDHURI: Thank you,

13 sir. I just want to point out, as the second part

14 of the proposal, bringing down the existing

15 language regarding 542 is still part of the

16 proposal because that language isn't framed as the

17 type of nonmandatory guidance that we're talking

18 about. It's framed as 542 minimum internal

19 controls. And so -- until that's taken down --

20 well, as it stands right now, the plain language

21 of that very well could be interpreted as being

22 inconsistent with some of the case law,

23 specifically the CRIT decision. So the idea is if

24 that's taken down, outside of case by case

25 assistance, what would be the intended --

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1 unintended consequences among those communities

2 that reference or that maybe have compacts

3 referencing those regulations?

4 So let me just say, I very much

5 appreciate those comments. There are impacts that

6 result from any one course of action. I mean,

7 there are impacts that result from doing nothing

8 to impacts resulting from doing a number of

9 different things. And that's what we're looking

10 at, and that's why we appreciate the input.

11 >> KEN MANY-WOUNDS: Now -- Ken

12 Many-Wounds again. Going back, I believe in the

13 California case, former chief of staff recommended

14 to a lot of these California tribes to put those

15 Class 3 minimum internal controls into your

16 compacts. Now they don't know what to do. But

17 that again was on the advice from a NIGC

18 representative at that time several, several

19 administrations back, which the compact is a state

20 government to government relationship. Those

21 tribes took the advice or the guidance at that

22 time of NIGC. Now they're in a pickle. And it's

23 not the other tribes' fault. It's really none of

24 their concern. So again, case by case, Mr.

25 Chairman, I understand my comment taking it off

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1 the website. I understand what you're saying

2 where there are tribes still affected by this.

3 But it shouldn't be -- it's those tribes who put

4 that language in there that in my opinion they

5 didn't get sound advice. What they did to

6 themselves, they did it to themselves. Now they

7 have to figure out a way to undo what they have

8 done. That's going back and negotiating probably

9 new compacts with the elimination of that Class 3

10 language. But will that be done? That will be a

11 big fight in California. Not all California

12 tribes did that. Just certain ones did it. So

13 again, my comments -- yours are well taken about

14 my comment wiping it off the website in lieu of

15 brother and sister tribes out in California. I

16 suppose it's got to stay up there for a while so

17 they can try and protect themselves for a while

18 but it's of no concern to (inaudible).

19 >> CHAIRMAN CHAUDHURI: Thank you

20 for those comments, Mr. Many-Wounds. Additional

21 comments? Okay.

22 With that I think we've had a very

23 healthy dialogue. As I mentioned before there's

24 no penalty for finishing early. And there is

25 certainly no requirement that we get all comments

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1 available on the record today. Written comments

2 are certainly acceptable and appreciated. But

3 with that, unless there are any requests

4 otherwise, I think we'll conclude today's formal

5 consultation. Thank you so much for taking the

6 time to be here today.

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1 C E R T I F I C A T E

2

3

4 I, LAUREN SCHECHTER, do hereby

5 certify that the foregoing is a true and accurate

6 transcript of a tape recording in this matter.

7 I do further certify that I am

8 neither of counsel nor attorney for any party in

9 this action and that I am not interested in the

10 event nor outcome of this litigation.

11

12

13

14

15

 _____________________________________________

16 Certified Shorthand Reporter for the State of

 New Jersey

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1

12 23:9

13175 9:16 10:4

15 9:17

1992 14:12 17:24

1999 18:25 20:15,17

28:4

2

2 11:20 24:5,9 43:15

45:1

20 27:18

2002 18:25 19:2

20:23 22:6 23:8

2013 23:8

2014 23:9

20th 12:7

25 20:21 45:9

28 27:17,19

2:03 2:2

3

3 18:18,23 19:6,13

19:19 20:1,16 21:1

21:21 22:11 23:13

23:19,24 25:10,13

26:9 41:23 42:16,24

43:16 44:10,15 45:1

46:15 47:9

30 27:19

30th 12:6

4

4 11:20

5

542 24:1,2,2,4,11

27:7 32:16,20 44:15

44:17 45:15,18

543 23:25 24:1,4,10

32:14,16,17,24 33:3

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water 24:24

way 9:2 21:20 23:19

30:12 40:4 47:7

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14:11,16 23:12 32:7

32:7 41:13 43:20

47:22

website 12:12 15:17

44:18 47:1,14

week 4:2 28:13 45:2

45:6

weigh 15:23 25:6

27:10 39:14 42:13

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38:23

went 6:9,16 11:6,12

21:10 22:5 41:17

wife 38:16

william 7:1,1

wiping 47:14

withdraw 19:15

20:4

wonderful 31:15

words 36:19

work 2:17 5:13 15:4

24:14 26:4,12 27:16

28:20 39:20,24

worked 9:16 10:6

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working 9:25 45:10

world 6:10

wound 5:11

wounds 6:19,23

8:24 9:6 12:20

17:20,21 20:11,12

26:9 29:17,18 31:24

35:15 36:14 37:20

38:20 39:2 43:23,24

46:11,12 47:20

write 24:23

writing 21:5 23:11

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www.nigc.gov 12:13

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year 22:7 44:17

years 9:14,17 11:4

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25:21 26:10,24

27:17,19,19,21

28:15 32:8 36:16,16

36:17

yesterday 6:10

young 27:22

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