(3) Chief of Security;
(4) Custodian of Gaming Supplies or cash;
(5) Floor Manager;
(6) Pit Boss;
(7) Dealer;
(8) Croupier;
(9) Approver of Credit; or
(10) Custodian of gambling devices including persons
with access to cash and accounting records within
such devices;
(b) If not otherwise included any other person whose total
cash compensation is in excess of $50,000 per year; or
(c) If not otherwise included, the four most highly
compensated persons in the gaming operation.

2. Primary Management Official means

(a) The person having management responsibility for a
management contract;
(b) Any person who has authority:
(1) To hire and fire employees; or
(2) To set up working policy for the gaming
operation; or
(c) The chief financial officer or other person who has
financial management responsibility.

B. Application Forms
1. The following notice shall be placed on the application form of a
key employee or primary management official before that form if
filled out by an applicant:

In 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 et seo. 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 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, Sherwood Valley Tribal Council, State, local, or
foreign law enforcement and 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 an employee, the
issuance or revocation of a gaming license, or investigations of activities
while associated with a tribe or gaming operation. Failure to consent to
the disclosures indicated in this notice will result in a tribe's being unable
to hire you in a primary management official or key employee position.


G. Granting a Gaming License

1. If, within a thirty (30) day period after the National Indian Gaming
Commission receives a report, the National Indian Gaming Commission
notifies the Sherwood Valley Tribal Council or its designated gaming
regulatory agency that it has no objection to the issuance of a license
pursuant to a license application filed by a key employee or a primary
management official for whom the Sherwood Valley Tribal Council or its
designated gaming regulatory agency has provided an application and
investigative report to the National Indian gaming Commission, the
Sherwood Valley Tribal Council or its designated gaming regulatory
agency may issue a license to such applicant.

2. The Sherwood Valley Rancheria Tribal Council or its designated
gaming agency shall respond to a request for additional information from
the Chairman of the National Indian Gaming Commission concerning a
key employee or a primary management official who is the subject of a
report. Such a request shall suspend the 30-day period under Subsection
G.1 of this Section until the Chairman of the National Indian Gaming
Commission receives the additional information.

3. If, within the thirty (30) day period described above, the National
Indian Gaming Commission provides the Sherwood Valley Tribal Council
with a statement itemizing its objection(s) to the issuance with a statement
itemizing its objection(s) to the issuance of a key employee or to a primary
management official for whom the Sherwood Valley Tribal Council or its
designated gaming regulatory agency has provided an application and
investigative report to the National Indian Gaming Commission, the
Sherwood Valley Rancheria Tribal Council or its designated gaming
regulatory agency shall reconsider the application, taking gaming
regulatory agency shall reconsider the application, taking into account the
objection(s) itemized by the National Indian Gaming Commission. The
Sherwood Valley Tribal Council shall make the final decision whether to
issue a license to such applicant.

H. License Suspension

1. If, after the issuance of a gaming license, the Sherwood Valley Tribal
Council or its designated gaming regulatory agency receives from the
National Indian Gaming Commission reliable information indicating that
a key employee or primary management official is not eligible for
employment under Subsection D above, the Sherwood Valley Tribal
Council or its designated gaming regulatory agency shall suspend such
license and shall notify in writing the licensee of the suspension and the
proposed revocation.


c. The names and current addresses of at least three
personal references, including one personal reference who
was acquainted with the applicant during each period of
residence listed under paragraph (1) (b) of this Subsection;

d. Current business and residence telephone numbers;

e. A description of any existing and previous business
relationships with Sherwood Valley Tribal Council,
including ownership interests in those businesses;

f. A description of any existing and previous business
relationships with the gaming industry generally, including
ownership interests in those businesses;

g. The name and address of every licensing or regulatory
agency with which the person has filed an application for a
license or permit related to gaming, whether or not such
license or permit was granted;

h. For each felony for which there is an ongoing prosecution
for a conviction, the charge, the name and address of the
court involved, and the date and disposition if any;

i. For each misdemeanor conviction or ongoing
misdemeanor prosecution (excluding minor traffic
violations) within ten years of the date of the application,
the name and address of the court involved and the date
and disposition;

j. For each criminal charge (excluding minor traffic
charges), whether or not there is a conviction, if such
criminal charge is within ten years of the date of the
application and is not otherwise listed pursuant to
paragraph (1) (h) or (1) (1) of this Subsection, the criminal
charge, the name and address of the court involved and the
date and disposition;

k. The name and address of any licensing or regulatory
agency with which the person has filed an application for an
occupational license or permit, whether or not such license
or permit was granted.

1. Photograph

m. Any other information the tribe deems relevant.


The disclosure of your Social Security Number (SSN) is voluntary.
However, failure to supply a SSN may result in errors in
processing your application.

2. Existing key employees and primary management officials shall
be noti
fied in writing that they shall either:

a. Complete a new application form that contains a Privacy
Act notice; or

b. Sign statement that contains the Privacy Act notice and
consent to the routine uses described in that notice.

3. The following notice shall be placed on the application form for
a key employee or primary official before that form is filled out by
an applicant:

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 you
may be punished by fine or imprisonment. (18 U.S.C. 1001).

4. The Sherwood Valley Tribal Council or its designated gaming
regulatory agency shall notify in writing existing key employees
and primary management officials that they shall either:

a. Complete a new application form that contains a notice
regarding false statements; or

b. Sign a statement that contains the notice regarding false
statements.

C. Background Investigations

1. The Sherwood Valley Rancheria Tribal Council or its designated
gaming regulatory agency shall request from each primary
management official and from each key employee all of the
following information:

a. Full name, other names used (oral or written), Social
Security number(s), birthdate, place of birth, citizenship,
gender, all languages spoken or written;

b. Currently and for the previous five years: all business
and employment positions held, ownership interests in
those businesses, business and residence addresses, and
drivers license numbers;


1. Pursuant to the procedures set out in Subsection E of this
section, the Sherwood Valley Tribal Council or its designated
gaming regulatory agency shall prepare and forward to the
National Indian Gaming Commission an investigative report on
each background investigation. An investigative report shall
include all of the following:

a. Steps taken in conducting the background investigation;
b. Results obtained;

c. Conclusions reached; and

d. The basis for those conclusions.

2. The Sherwood Valley Tribal Council or its designated gaming
regulatory agency shall submit, with the report, a copy of the
eligibility determination made under subsection D of this section.

3. Ifa license is not issued to an applicant, the Sherwood Valley
Tribal Council or its designated gaming regulatory agency:

a. Shall notify the National Indian Gaming Commission;
and

b. May forward copies of its eligibility determination and
investigative reports (if any) to the National Indian Gaming
Commission for inclusion in the Indian Gaming Individuals
Records System.

4. With respect to key employees and primary management
officials, the Sherwood Valley Rancheria Tribal Council or its
designated gaming regulatory agency shall retain applications for
employment and reports (if any) of background Investigations for
inspection by the Chairman of the National Indian Gaming
Commission or his or her designee for no less than three (3) years
from the date of termination or denial of employment.


NATIONAL

ig

B
Uj INDIAN OCT - 2 1995
GAMING

© COMMISSION

Mike Knight

Chairman

Sherwood Valley Rancheria
190 Sherwood Hill Drive
Willits, CA 95490

Dear Chairman Knight:

This letter responds to your request to review and approve
the tribal gaming ordinance, Resolution No. 95-5-31, adopted on
May 31, 1995, by the Sherwood Valley Rancheria (Tribe). This
letter constitutes such approval under the Indian Gaming
Regulatory Act (IGRA).

Under the IGRA and the regulations of the National Indian
Gaming Commission (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 Chairman's
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 Chairman's approval of the Tribe's gaming
ordinance, the Tribe is now required to conduct background
investigations on its key employees and primary management
officials. The NIGC expects to receive a completed application
for each key employee and primary management official pursuant to
25 C.F.R. § 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.

§ 556.5(b).

Thank you for submitting the ordinance of the Sherwood
Valley Rancheria for review and approval. The NIGC staff and I
look forward to working with you and the Tribe in implementing
the IGRA.

Sincerely yours,

Chairman

1850 M STREET. NW. SUITE 250 WASHINGTON DC 20036 TEL 202-632-7003 FAX _202-632-7066



D. The Sherwood Valley Rancheria Tribal Council Gaming Commission
shall be authorized and hereby ‘is directed to promulgate, subject to
review and approval by the Tribal Council, detailed and comprehensive
regulations for the implementation and enforcement of this ordinance.
Said regulations shall describe and establish the rules for each specific
Class II and Class III gaming activity to be authorized to be conducted on
the Sherwood Valley Rancheria, and no form of such gaming may be
conducted on the Sherwood Valley Rancheria without prior approval by
the Sherwood Valley Rancheria Tribal Council Gaming Commission.
Pending approval of the Sherwood Valley Rancheria Tribal Council
Gaming Commission’s any interim regulations that the Sherwood Valley
Rancheria Tribal Council may adopt shall govern gaming on the
Rancheria.

E. The Sherwood Valley Rancheria Tribal Gaming Commission,
independent of the General Council, shall have full authority to monitor
compliance with this Ordinance and its regulations, and to investigate
and act to prevent any violation(s) thereof.

F. Subject to the approval of the tribal Council and the appropriation of
funds therefor, the Sherwood Valley Rancheria Tribal Council Gaming
Commission shall be authorized to employ such staff as reasonable may
be required to fulfill its responsibilities under this ordinance.
Compensation of commission employees shall be limited to that which is
comparable to compensation paid to persons performing similar duties in
other governmental gaming regulatory agencies.

G. Subject to the approval of the Tribal Council, the Sherwood Valley
Rancheria Tribal Council Gaming Commission hereby is authorized to
establish and impose upon gaming facilities, permits, applicants and
licensees such application, permit and license fees as may be necessary to
fully reimburse the Sherwood Valley Rancheria Tribal Council Gaming
Commission, enforcing this ordinance and Sherwood Valley Rancheria
Tribal Council Gaming Commission regulation, processing and licensing
and permit applications, and otherwise fulfilling its regulatory
responsibilities under IGRA. All such fees shall be collected by the
Sherwood Valley Rancheria Tribal Council Gaming Commission and
hereby are continuously appropriated solely for the purposes enumerated
in this Subsection.

10


2. The Sherwood Valley Tribal Council or its designated gaming
regulatory agency shall notify the licensee of a time and place for a
hearing on the proposed revocation of a license.

3. After a revocation hearing, the Sherwood Valley Tribal Council or is
designated gaming regulatory agency shall decide whether to revoke or
to reinstate a gaming license. The Sherwood Valley Tribal Council shall
notify the National Indian Gaming Commission of its decision.

VIII. Licensing of Gaming Places, Facilities and Locations

A separate license shall be required for each place, facility, or location on Indian
lands where Class II and/or Class II gaming is to be conducted on the
Sherwood Valley Rancheria.

IX. Creation of Sherwood Valley Rancheria Tribal Council Gaming
Commission

A. There is hereby created the Sherwood Valley Rancheria Tribal Council
gaming Commission, which shall consist of three persons who would
themselves qualify for licensing under this Ordinance.

B. The members of the Sherwood Valley Rancheria Tribal Council
Gaming Commission shall be appointed by the Sherwood Valley
Rancheria Tribal Council, and shall not be removed during the terms of
office except for misconduct, neglect of duties or other acts that would
render such persons unqualified for licenser thereunder. An affirmative
vote of at least four members of the Sherwood Valley Rancheria Tribal
Council, taken in an open meeting after a duly-noticed hearing at which
the member charged with misconduct shall have the right to hear and
present evidence concerning his/her removal, shall be required to remove
a member of the Commission. At the request of the member whose
removal is at issue, the hearing may be held in executive session. The
Sherwood Valley Rancheria Tribal Council also may elect to receive in
executive session any evidence public disclosure of which might
compromise any on-going law-enforcement investigation, or which might
jeopardize any privilege or immunity possessed by the Sherwood Valley
Rancheria Tribal Council.

C. There shall be a chairperson of the Sherwood Valley Rancheria Tribal
Council Gaming Commission, who shall be appointed for a term of two
years. The remaining members of the Commission shall be appointed for
terms of one year. The Tribal Council shall determine and authorize the
compensation to be paid to members of the Sherwood Valley Rancheria
Tribal Council Gaming Commission based upon the Tribal Council’s
determination of the time required to be expended upon Commission
duties and the qualifications of the appointed Commissioners.


n. Fingerprints consistent with procedures adopted by the
tribe.

2. The Sherwood Valley Tribal Council or its designated gaming
regulatory agency shall conduct an investigation sufficient to make
a determination under Subsection D, below. In conducting a
background investigation, the Tribal Council or its agent(s) shall
promise to keep confidential the identity of each person
interviewed in the course of the investigation.

D. Eligibility Determination

The Sherwood Valley Tribal Council or its designated gaming regulatory
agency shall review a applicant's prior activities, criminal record, if any,
and reputation, habits and associations to make a finding concerning the
eligibility of a key employee or primary management official for
employment in a gaming operation. If the Sherwood Valley Rancheria
Tribal Council or its designated gaming regulatory agency determines
that employment of the person poses a threat to the public interest or to
the effective regulation of gaming, or creates or enhances dangers of
unsuitable, unfair, or illegal practices and methods and activities in the
conduct of gaming, the gaming operation shall not employ that person in
a key employee or primary management official position.

E. Procedures for Forwarding Applications and Reports for Key
Employees and Primary Management Officials to the National Indian
Gaming Commission

1. When a key employee or primary management official begins
work at a gaming operation authorized by this Ordinance, the
Sherwood Valley Tribal Council or its designated gaming agency
shall forward to the National Indian Gaming Commission a
completed application for employment and conduct the
background investigation and make the determination referred to
in Subsection D of this Section.

2. The Sherwood Valley Tribal Council or its designated gaming
regulatory agency shall forward the report to in Subsection F of
this Section to the National Indian Gaming Commission within 60
days after an employee begins work or within 60 days of the
approval of this ordinance by the Chairman of the National Indian
Gaming Commission.

3. The gaming operation shall not employ as a key employee or
primary management official a person who does not have a license

after 90 days.

F. Report to the National Indian Gaming Commission


4. donate to charitable organizations; or
5. help fund operations of local government agencies.

B. If the Sherwood Valley General Council elects to make per capita
payments to Sherwood Valley Tribal members, it shall authorize such
payments only in conformity with a plan submitted to and approved by
the Secretary of the Interior pursuant to 25 U.S.C. 2710 (b) (3).

V. Audit
A. The Sherwood Valley Rancheria Tribal Council shall cause to be
conducted at least annually in independent audit of all gaming operations
and shall submit the resulting audit reports to the National Indian
Gaming Commission, and to such other agencies as may be required by
the terms and conditions of any Class III compact or other document
authorizing Class II gaming on the Sherwood Valley Rancheria.

B. All gaming-related contracts that result in the purchase of supplies,
services, or concessions in excess of $25,000.00 annually, except contracts
for professional legal and accounting services, shall be specifically
included within the scope of the audit that is described in Subsection A
above.

VI. Protection of the Environment and Public Health and Safety

Class II and Class III gaming facilities on the Sherwood Valley Rancheria shall be
constructed, maintained and operated in a manner that adequately protects the
environment and the public health and safety, with the Sherwood Valley Tribal
Council having primary responsibility for assessing the environmental impact of
all construction and gaming operations, and taking such measures as it
determines may be reasonably necessary to mitigate any adverse environmental
impacts as it may identify.

VII. Licenses for Key Employees and Primary Management Officials

The Sherwood Valley Rancheria Tribal Council or its designated gaming
regulatory agency shall ensure that the policies and procedures set out in this
section are implemented with respect to key employees and primary
management officials employed at any Class II and/or Class II gaming
enterprise operated on Indian lands within the boundaries of the Sherwood
Valley Rancheria:

A. Definitions
For the purposes of this section, the following definitions apply:
1. Key Employee means
(a) A person who performs one or more of the following
functions:
(1) Bingo Caller;
(2) Counting Room Supervisor;


Sherwood Valley Rancheria
Gaming Ordinance

I. Purpose

The Sherwood Valley Rancheria Indians as the beneficial owner of the Sherwood
Valley Rancheria, and acting through its General Council in the exercise of its
inherent sovereign power to enact ordinances and otherwise safeguard and
provide for the health, safety and welfare of the Sherwood Valley Rancheria and
the members of the Sherwood Valley Tribal Council, hereby ordains and
establishes this ordinance for the purpose of authorizing and comprehensively
and preemptively regulating the terms and conditions under which Class II and
Class Il gaming may be conducted within the boundaries of the Sherwood
Valley Rancheria.

II. Gaming Authorized
A. Class II gaming as defined in the Indian Gaming Regulatory Act, P.L.
100-447, 25 U.S.C. Section 2703 (7) (A) (“IGRA”) and by regulations
lawfully promulgated by the National Indian Gaming Commission
(“NIGC”) that now or hereafter may be in effect is hereby authorized.

B. Class III gaming as defined in IGRA, 25 U.S.C. Section 2703 (8) and by
regulations promulgated by the NIGC that now or hereafter may be in
‘effect if hereby authorized, provided such gaming is also authorized by
and consistent with a Tribal-State Compact that has been approved by the
Secretary of the Interior and is in effect, or otherwise has been authorized
by the Secretary of the Interior or federal law.

Ill. Ownership of Gaming Facilities and/or Enterprises

The Sherwood Valley Tribal Council shall have the sole propriety interest in and
responsibility for the conduct of any gaming facilities and/or enterprise(s)
authorized by this ordinance.

IV. Use of Gaming Revenue
A. Except as specifically authorized pursuant to Subsection B of this
Section, net revenues from Class II and Class III gaming on the Sherwood
Valley Rancheria shall be used only for the following purposes:

1. to fund Sherwood Valley Rancheria Tribal Council government
operations and programs;

2. provide for the general welfare of the Sherwood Valley
Rancheria and its members;

3. promote Sherwood Valley Rancheria Tribe economic
development;


INDIAN GAMING REGULATORY ACT
RESOLUTION AUTHORIZING THE SUBMISSION OF THE TRIBE’S
GAMING ORDINANCE

RESOLUTION # 95-5-31

WHEREAS: the Sherwood Valley Rancheria Indians is a
federally recognized Indian Tribe by the Secretary
of the Interior as a Sovereign Indian Nation with
inherent powers of self-government; and

WHEREAS: the Sherwood Valley Rancheria Indians has a great
need for economic development on the Sherwood
Valley Rancheria and views gaming as a legitimate
means for generating revenue; and

WHEREAS: the Sherwood Valley Rancheria is desirous of
compliance with the Indian Gaming Regulatory Act;
and

WHEREAS: the Sherwood Valley Rancheria is desirous of

engaging in the operation of gaming on the Sherwood
Valley Rancheria; and

NOW, THEREFORE BE IT RESOLVED, that the Sherwood Valley Rancheria
does hereby submit for review and authorization of it’s gaming
ordinance.

CERTIFICATION

The Tribal Council of the Sherwood Valley Rancheria does hereby
certify that at a meeting duly called, noticed, and convened on
the 31st day of May, 1995, where a quorum was present, this
action was duly adopted by a vote 5 for, 0 against, and 0

abstaining.
DUA. Yamane Lonrilicg
MIKE KNIGHT} c ATTEST

b-209S S-3)-95-

DATE DATE

190 Sherwood Hill Drive ¢ Willits, California 95490
(707) 459-9690 © Fax (707) 459-6936


H. Failure to timely pay any gaming-related fee imposed by the Tribal
Council or the Sherwood Valley Rancheria Tribal Council Gaming
Commission, or to comply with any Commission regulation on order, or
any other violation of this ordinance or the terms of any Class III gaming
compact authorizing and regulating gaming on the Sherwood Valley
Rancheria shall be grounds for suspension or revocation of any license or
permit issued pursuant to this Ordnance, exclusion of any non-member of
the Sherwood Valley Rancheria, from the Sherwood Valley Rancheria,
and imposition of such other sanctions as the Sherwood Valley Rancheria
Tribal Council Gaming Commission may deem appropriate.

I Any person or entity subject to any sanction or penalty by the
Sherwood Valley Rancheria Tribal Council Gaming Commission shall
have the right to appeal such sanction or penalty to the Tribal Council in
accordance with such rules and regulations as may be promulgated by the
Tribal Council for that purpose. The decision of the Tribal Council on any
appeal shall be final and nor otherwise revisable.

X. Repeal

To the extent that they are inconsistent with this ordinance, all gaming
ordinances previously enacted or amended by the Sherwood Valley Rancheria
Tribal Council hereby are repealed.

Certification

This is to certify that the foregoing Ordinance was adopted on

3l, ata duly-called meeting of the Sherwood Valley Tribal
Council at which a quorum was present, by vote of __ 5” in favor,
opposed and abstaining.

yn a Sammy Cortes

Tribal Chairman Tribal Secretaty

May_31 FE, 19US- MNGYy_ 3) ([9FGE-

Date 0 Date