NOTICE OF VIOLATION 

Ref No. : NOV-98- 12 

VIA FAX AND CERTIFIED MAIL 

To: James Billie, Chairperson 

Seminole Tribe of Florida 

6300 Stirling Road 

Hollywood, FL 33024 

Fax (954) 967-3486 

Respondent 

w . 1. Under National Indian Gaming Commission (hereinafter referred to as the "NIGC") 

regulations, the Chairman may issue a notice of violation to any person for violation of any 

provision of the Indian Gaming Regulatory Act (hereinafter referred to as "IGRA") or 

NIGC regulation or any provision of the tribal ordinance or resolution approved by the 

Chairman. 25 C.F.R. 573.3. 

2. The Chairman hereby gives notice that the Seminole Tribe of Florida (hereinafter referred 

to as the "Tribe" or the "Respondent") is in violation of IGRA, NIGC regulations, and its 

tribal gaming ordinance. 

3. On December 3, 1993, the NIGC Chairman approved the Tribe's Gaming Ordinance C-02- 

94 (hereinafter referred to as the "Approved Ordinance"). Section 15-1 (c) of this 

Approved Ordinance provides for the submission of audit reports to the NIGC. 

4. The Respondent is in violation of IGRA, NIGC regulations and the Approved Ordinance 

as follows: 

a. The IGRA states that a tribe may engage in gaming if, among other requirements, 

a tribe's approved gaming ordinance requires submission to the NIGC of an annual 

independent audit of the gaming operation. 25 U.S.C. 3 2710(b)(2) and (d)(2). 

NIGC regulations require that a tribe cause to be conducted annual independent 

audits of the financial statements of each gaming operation on Indian lands and 

1441 L STREET, N.W. QTH FLOOR WASHINGTON, D.C. 20005 EL.: 202-632-7003 FAX: 202-632-7066 
submit a copy of the audit report(s) and any management letter(s) setting forth the 

results of the annual audit(s) to the to the NIGC within 120 days after the end of 

each fiscal year. 25 C.F.R. $5 571.12-13. In addition, 15-1 (c) of the Approved 

Ordinance requires that the Tribe submit these annual independent audits to the 

NIGC. 

b. As of the date of this Notice of Violation (hereinafter referred to as "NOV"), the 

NIGC has not received the Respondent's audit report and management letter for 

Brighton Seminole Bingo for the fiscal year ended June 30, 1997. This audit 

report was due to the NIGC no later than October 28, 1997. Because of this 

failure to submit the audit report to the NIGC by the required deadline, the 

Respondent is in violation of IGRA, NIGC regulations and its Approved 

Ordinance. 

5. The measures required to correct the ongoing violation are: 

The NIGC must receive the audit report and any management letter for Brighton Seminole 

Bingo for the fiscal year ended June 30, 1997, within ten (10) days. The audit report 

should be submitted to: Chairman, National Indian Gaming Commission, 1441 L Street, 

NW, 9th Floor, Washington, DC 20005. 

IwrY 

6. The violations cited in this NOV may result in the assessment of civil fines against the 

Respondent in an amount not to exceed $25,000 per violation per day. Under 25 C.F.R. 

5 575.5(a), the Respondent may submit written information about the violations to the 

NIGC Chairman within 15 days after service of this NOV (or such longer period as the 

NIGC Chairman may grant for good cause). The NIGC Chairman shall consider any 

information submitted in determining the facts surrounding the violations and the amount 

of the civil fine, if any. Such information should be submitted to the address set forth in 

paragraph 5. 

7. The Respondent may appeal the allegations contained in this NOV to the NIGC within 30 

days after service of this NOV. 25 C.F.R. Part 577. The Respondent may appeal the 

allegations by submitting a Notice of Appeal to the NIGC at the address set forth in 

paragraph 5 above. The Respondent has a right to be represented by counsel in such an 

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

Notice of Appeal, the Respondent must file with the NIGC a supplemental statement that 

states with particularity the relief desired and the grounds therefore and includes, when 

available, supporting evidence in the form of affidavits. 

If the Respondent wishes to present oral testimony or witnesses at a hearing, the 

Respondent must include a request to do so with the supplemental statement. The request 

to present oral testimony must specify the names of the proposed witnesses and the 

general nature oftheir expected testimony, and whether a closed hearing is requested and 
why. The Respondent may waive the right to an oral hearing and instead elect to have the 

matter determined by the NIGC solely of the basis of the written submissions. 

8. A copy of the regulations cited in this NOV is attached for your information. 

e 

7" I .J \' -, APR - 2 1998 

Tadd M Johnson, chairman Date 

National Indian Gaming Commission 

Richard B. Schiff, NIGC Attorney 

(202) 632-7003 

Fax (202) 632-7066