NATIONAL INDIAN GAMING COMMISSION 

NOTICE OF VIOLATION 

TO: Lac Courte Oreilles Band of Lake Superior Chippewa Indians of Wisconsin 

Attn: Louis Taylor, Sr., Chairman 

Agent for Service of Process 

I3394 W. Trepania Road 

Hayward, Wisconsin 54843 

FAX: (77 5) 634-8934 

Lac Courte OreilEes Gaming Commission 

Attn: James Smith, Executive Director 

13394 W. Trepania Road 

Hayward, Wisconsin 54843 

FLY: (715) 634-9433 

F=ris Goodwill, Tribal Attorney 

13394 W. Trcpania Road 

Hayward, Wisconsin 54843 

FLY: (715) 634-9433 

1. Notification of Violation 

Thc Chairman of the National Indian Gaming Commission (NTGC) hercby gives 

notice that the La Courte Oreilles Rand of Lake Superior Chippewa Indians of 

Wisconsin (Respondent or Tribe). Iocated in Hayward, Wisconsin, has violated 

NIGC regulations by failing to submit a timely annual audit. 

Under the Indian Gaming Regulatory Act (IGRA) and NGC regulations, the 

Chainnan of the NIGC (Chairman) may issue a Notice of Violation (NOV) to any 

person for violation oC any provision of the IGRA, NIGC regulations, or any 

proxrision of a tribal gaming ordinance or resoIution approved by the Chairman. 

25 W.S.C. $2713; 25 C.F.R. 5 573.3. 
3. Applicable Federal Laws and TribaI Ordinance Provisions 

A. IGRA requires an annuaI audit of each garning operation and requires that 

copy of the results of the annual audit be submitted to the NIGC. 25 

U.S.C. 5 27 I O(b)(2)(C). 

R. NIGC regulations require that a tribe cause to he conducted annual 

independent audits oi' the financid statements of each gaming operation on 

Indian lands and submit a copy of the audit repodds) and any management 

Pettcr(s) setting forth the results of the annual audit(s) to the NIGC within 

1 20 days after the end of each gaming operation's fiscal year. 25 C.F.R. 

$3 571.12 and 571.13. 

C. NIGC regulations define "gaming operation" as "each economic entity 

that is licensed by a tribe, operates the games. receives the revenues, 

issues the prizes and pays the expenses."" A gaming operation may be 

operated by a tribe directly; by a management contractor; or. under certain 

conditions. by another person or other entity. 25 C.F.R. 5 502.10. 

4. Role of Independent Audit Report 

Submission of the annual independent audit report by a firm of certified pubIic 

accountants is criticaI to the NIGC's mission to protect the integrity of Indian 

gaming. A firm's ability to conduct an audit in accordance with generally 

accepted auditing standards and render an opinion on the financial statements 

prepared in conformity with generatIy accepted accounting principles provides a 

certain level of assurance as to the security of tribal gaming revenues. The audit 

report prepared and submitted on a timely basis is evidence of, among other 

things, the integrity of the gaming operation and, more specifically, of the 

adequacy of the hooks and records, the functioning of the internal financial 

controls. and the disclosure of information having a bearing on the financial 

statements. 

5. Circumstances of the Violation 

A. Respondent is a federally recognized Indian Tribe with tribal headquarters 

in Hayward. Wisconsin. 

B. The Tribe operated its gaming operation, Lac Courte Oreilles Grindstone 

Creek Casino. during all or part of 2007. 

C. The Tribe operated its gaming operation, Lac Courte Oreilles 

CasinolLodge and Convention Center, during all or part of 2007. 

D. lGRA requires that tribes submit annual audits of each tribal gaming 

operation. 25 U.S.C. 5 271 0(b)(2)(C). NTGC regulations require that a 
tribe cause to be conducted an annual independent audit of the financial 

statements of each gaming operation on Indian lands and submit a copy of 

the audit reprtrs) and management letter(s) setting forth the results of the 

mnuaI audit(s) to the NFGC within 120 days after the end of each gaming 

operation's fiscaI year. 25 C.F.R. $8 571.1 2.571.13. 

E. The fiscal years for the gaming operations named in this violation ended 

March 3 1.2008. 

F. The audit reports for the gaming operations named in this violatian were 

due to NIGC on or before July 29,2008. 

G. NIGC received the audit reports for these gaming operations on August 

26,2008.28 days late. 

34. The Tribe is in violation of NIGC regulations for failure to submit timely 

annual independent audit reports. 

6. Measures Required to Correct the Violation 

Audits must be received within 120 days of the end of a gaming operations fiscal 

year. 25 C.F.R. 4 57 1.7 3. While thcre is no remedial action that can correct the 

untimeIy filing of the audit reports. improved controls to ensure timely 

submission of the next audit reports should he put in place. 

Within thirty (30) days after service of this Notice of Violation, Respondent may 

appeal to the fill Commission under 25 C.F.R. Part 577 by submitting a notice of 

appeaI. and, if desired, request for hearing to the National Indian Gaming 

Commission. 144 1 L Street N W, Ninth Floor, Washington, BC 20005. 

Respondent has a right to assistance of counseI in such an appal. A notice of 

appeaI must reference this Notice of VioIation. 

Within ten (I 0) days after filing a notice of appeal. Respondent must fiIe with the 

Commission a supplernentd statement that states with particularity the relief 

desired and the grounds therefore and that includes, when available, supporting 

evidence in the iorm of affidavits. If Respondent wishes to present oral testimony 

or witnesses at the hearing, Respondent must incIude a request to do so with the 

supplemental statement. The request to present oral testimony or witnesses must 

specify the names of proposed witnesses and the general nature of their expected 

testimony, whether a closed hearing is requested and why. Respondent may 

waives its right to an oral hearing and instead elect to have the matter determined 

by the Commission solcIy on the basis of written submissions. 
8. Fine-Submission of Information 

The violation cited above may result in the assessment af a civiI fine against 

Respondent in an amouni not to exceed $25,000 per vioIation per day. Under 25 

C.F.R. $ 575.5(a3, Respondent may submit written information about the violation 

to the Chairman within fifteen (1 5) days after service of this notice of violation 

(or such longer period as the Chairman may pnt for good cause). The Chairman 

shaII consider any information submitted in determining the facts surrounding the 

violation and the amount of the civil fine, if any. 

Dated this I of October, 2008 -- 

I 

PRLIP N. I-IOGEN 

Chairman 

HER'I'I IIJR L. MCMILLAN 

Staff Attorney 
Certificate of Service 

I certify that this Notice of Violation was sent by facsimile transmission and certified 

U.S. mail. return receipt requesrcd. on this 1w day of October. 2008 to: