FILED - Turtle Talk€¦ · Cummings, Craig Dillon, Stanley Little White Man, Bernie Shot With...

FILED William J. Bielecki, Sr., Pro Se P.O. Box 1990 JUN 0 5 2013 Pine Ridge, SD 57770 (605) 867-5028 ~~ Co-Plaintiff

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH DAKOTA

WESTERN DIVISION

Patrick A. Lee; Floyd Hand; William J. Bielecki , Sr.,) each as individuals, pro se. )

) )

Plaintiffs, ) )

vs. )

Robert Ecoffey, Superintendent of Bureau of Indianj Affairs, Pine Ridge Agency, Pine Ridge Indian) Reservation, South Dakota, as BIA Superintendant; and )

) Ruth Brown, Jim Meeks, Charles L. Cummings, Craig) Dillon, Stanley Little White Man, Bernie Shot With) Arrow, Paul Little, Barbara Dull Knife, James Cross,) Lydia Bear Killer, Danielle "Dani" Lebeau, Troy "Scott") Weston, Dan Rodriguez, Jacqueline F. Siers, Garfield) Steele, Kevin Yellow Bird-Steele, Irving Provost, RObinj Tapio, Lawrence "Larry" Eagle Bull, John Hass, Bette) Goings and Tatewin Means, "each as individuals" )

) Defendants )

) )

Case No.

Civ.13-S019-JLV

PLAINTIFFS' RESPONSE IN OPPOSITION TO (TRIBAL)

DEFENDANTS' MOTION TO DISMISS AND

INDIVID UAL DEFENDANTS' RESPONSE IN OPPOSITION FOR DEFAULT JUDGMENT AND DECLARATORY AND INJUNCTIVE

RELIEF

ORAL ARGUMENTS REQUESTED

TO: See Attached Service List:

NOW COMES Patrick A. Lee, Floyd Hand, and William 1. Bielecki, Sr., individuals, pro se,

and Plaintiffs in the above captioned case, and hereby submits their RESPONSE IN

OPPOSITION TO TRIBAL DEFENDANTS' MOTION TO DISMISS, AND MOTION TO

STRIKE INDIVIDUAL DEFENDANTS' MOTION TO DISMISS, and in support thereof,

states as follows:

Pit's Response In Opposition To (Tribal) Defs' Motion To Dismiss of 14

Case 5:13-cv-05019-JLV Document 32 Filed 06/05/13 Page 1 of 14 PageID #: 570

1. The complaint was amended (l SI Amended Complaint) adding Ruth Brown, Jim Meeks, Charles

L. Cummings, Craig Dillon, Stanley Little White Man, Bernie Shot With Arrow, Paul Little, Barbara

Dull Knife, James Cross, Lydia Bear Killer, Danielle "Dani" Lebeau, Troy "Scott" Weston, Dan

Rodriguez, Jacqueline F. Siers, Garfield Steele, Kevin Yellow Bird-Steele, Irving Provost, Robin

Tapio, Lawrence "Larry" Eagle Bull, John Haas, Bette Goings and Tatewin Means (collectively

"Tribal defendants"), and filed on April 03, 2013 (see item 9 on docket report), hereinafter

referred to as "Added Defendants";

2. Each of the added parties had been served through a process server on April OS, 2013 (see

item 11 on docket report), thereby requiring their answers within 21 days or April 26, 2013.

3. While the Complaints refer to Exhibits 1-5, the "Tribal Defendants" had been in possession

of Exhibits 1,2, 3 and 4 since March OS, 2013 (see file stamps on item 1 (Exhibit 1) on

docket report). Furthermore, Exhibits 1,2, 3 are the foundation for this federal law suit;

4. On April 23, 2013 @ about 12:45 MST, each of the Plaintiffs received a telephone call, in

turn, from Attorney's Mr. John T. Plata and Jennifer P. Hughes, of the law firm Hobbs,

Straus, Dean and Walker, LLP of Washington D.C., requesting a continuance for "Added

Defendants" filing their answers.

5. Mr. Plata and Miss Hughes were on a speaker telephone when asking for an agreed motion

for a continuance in the "Added Defendants' filing their answers, which was due on April 26.

2013;

6. Mr. Bielecki asked both attorneys specifically what are the names of their clients, and they

refused to provide the names, stating you will find out when we file an appearance;

7. Attorneys Mr. Plata and Miss Hughes continued to say that they will represent them all,

implying that all 22 added defendants, excluding Robert Ecoffey, and that they are in the

process of trying to confirm their relationship from each added defendant;

PIt's Response In Opposition To (Tribal) Defs' Motion To Dismiss of 14


8. Plaintiffs believe that attorneys Mr. Plata and Miss Hughes has violated ethical rules in

seeking legal actions by:

a. Refusing to disclose clients' names;

b. By disguising their true purpose in seeking a continuance (ambulance chasing in a

manner of speaking) in that they themselves did not know who their clients were at

the time, and sought additional time to secure clients, rather than extended time in

critiquing the pleadings.

9. On April 25, 2013, Plaintiffs were served copies of an appearance by Attorney James P.

Hurley of BANGS, McCULLEN, BUTLER, FOYE & SIMMONS, LLP along with motions

to admit, pro hoc vice, Attorneys John T. Plata and Jennifer P. Hughes, of the law firm

HOBBS, STRAUS, DEAN AND WALKER, LLP from Washington DC, and a copy of

defendants' motion for an extension of time in filing their answers.

10. Upon receiving said notice of appearance, Plaintiff Patrick Lee discovered that a "Conflict of

Interest" existed with Attorney James P. Hurley and the law firm of BANGS, McCULLEN,

BUTLER, FOYE & SIMMONS, LLP, due to members of the firm managing prior legal

affairs of Mr. Lee.

11. Subsequently, Mr. Lee informed Mr. Hurley of the potential conflict, and Mr. Hurley stated

he would withdraw from the case;

12. On April 26, 2013 (answers were due), Mr. Hurley filed a joint motion to withdraw and a

substitution of counsel (see item 19 of docket report) :

the undersigned attorney hereby notifies the Court and counsel that the individually named Defendants, Ruth Brown, Jim Meeks, Charles L. Cummings, Craig Dillon, Stanley Little White Man, Bernie Shot With Arrow, Paul Little, Barbara Dull Knife, James Cross, Lydia Bear K.iller. Danielle "Dani" LeBeau, Troy "Scott" Weston, Dan Rodr iguez. Jacqueline F. Siers, Garfield Steele, Kevin YelJo\v Bird-Steele. Irving Provost, Robin Tapio. Lavvrence "Larry" Eagle Bull, John Hass. Bette Goings, and Tatewin Means, have retained Michael C. Loos of the Clayborne, Loos and Sabers,



LLP La,,\,' Firm to substitute as counsel for James P. Hurley of the Bangs, McCullen, Butler, Foye & Simmons. L.L.P. Law Firm in this case.

13. On April 29, 2013, new counsel (Michael Loos) for the Tribal Defendants filed renewed

motions to admit, pro hoc vice, Attorneys John T. Plata and Jennifer P. Hughes, of the law

firm HOBBS, STRAUS, DEAN AND WALKER, LLP from Washington DC, however,

failed to renew his motion for an extension of time for filing defendants' answers (see item

20 & 21 of docket report).

14. This honorable Court should take JUDICIAL NOTICE as to the fact that defendants', being

represented by new counsel, [£Jailed to renew their motion for an extension of time of which

to file their answers (emphasis added), although they did renew their motion for Washington

attorneys representing them pro hoc vice.

15. On May 13, 2013, Tribal Defendants' filed their motion entitled: [Individual Defendants'

Amended Motion For Extension Of Time To Answer], however, said motion was filed 17

days after the mandated due date of their required answers (see item 26 of docket report).

Additionally, said motion was filed the same day that the Plaintiffs filed their Motion For

Default Judgment (see item 27 of docket report);

16. Each of the defendants has had more than ample time of which to seek counsel and prepare

answers. Mr. Hurley's statement (see item 14 of docket report) that: [ ... The attorneys for the

individually named Defendants, were only authorized in writing to work on this matter for

our clients on April 22, 2013 ... ] clearly demonstrates the named defendants' had

intentionally procrastinated in seeking counsel, and they should not be rewarded.

17. WHEREFORE, Plaintiffs Patrick A. Lee, Floyd Hand, and William 1. Bielecki, Sr., after

discussion with one and another, each respectfully pray upon this Honorable Court to

DISMISS AND STRIKE Tribal defendants' motion entitled "Individual Defendants'



Motion To Dismiss", and deny said named defendants any continuance for filing their

answers beyond the required due date of April 26, 2013. Furthermore, Plaintiffs ask this

Honorable Court to grant a Default Judgment pursuant to Plaintiffs Motion For Default

Judgment and Declaratory and Injunctive Relief for reasons stated above and in their motion

for default judgment (see item 27 of docket report).

PLAINTIFFS' RESPONSE IN THE ALTERNATIVE

18. First, each of the Plaintiffs' deny that Mr. Bielecki has indicated in any way that he IS

representing anyone in this federal law suit other than himself, and that he is acting pro se in

every respect of the word. Each of the Plaintiffs' acknowledge that Mr. Bielecki has/is

representing Mr. Floyd Hand and Chief Judge Patrick Lee strictly within the Tribal

jurisdiction in light of the fact that he is a lawfully licensed advocate within said jurisdiction

and may lawfully do so (see Exhibit 1, docketed as 1-1).

19. Tribal Defendants' cite standing and ripeness of matters as a bar before this federal court,

however, a review of Exhibit 1, was inured into the pleadings by reference pursuant

Fed.R.Civ.P. 1O(c), of plaintiffs' Amended Complaint at ~28, and clearly identifies ripeness

of matters before this court (approx. III violations). Plaintiffs clearly assert actions taken

against them, and seeks declaratory and injunctive relief, rather than financial compensation.

20. Tribal Defendants' also cites Fed.R.Civ.P. 12(b)(l) as a bar to federal jurisdiction because

there is neither diversity, nor a federal question, however, because Plaintiffs are seeking

enforcement of the Tribal Constitution, the same said constitution, that governs the behavior

and activities of both members and non-members alike. While Tribal Councils and



Judiciaries may be limited in adjudicative actions against non-members and/or non-Indians,

non-the-Iess, Tribal Constitutions still grant Tribal Councils certain authority and judicial

power over non-Indians. Additionally, Plaintiffs' cited 25 USC 1301-3, as amended, et seq.

(Indian Civil Rights Act "ICRA") in their jurisdictional statement which includes § 1302(f),

as follows:

[25 USC § 1302 - CONSTITUTIONAL RIGHTS (I) Effect of section Nothing in this section affects the obligation of the United States, or any State government that has been delegated authority by the United States, to investigate and prosecute any criminal violation in Indian country.]

Clearly the US Congress has expanded the jurisdiction of federal courts to adjudicate

[a]ny criminal violation in Indian Country, which ... at the minimum.. . raises federal

questions.

21. Tribal Defendants' also cite in their motion to dismiss, a bar to federal jurisdiction based on

sovereign immunity, then a bar for failure to state a claim of which a relief can be granted in

the defendants' individual capacity. The Plaintiffs' assert that the civil aspect of this law suit

against the Tribal Council members is pursuant the Ex Parte Young (1908) "Splitting

Doctrine" (see Vann et al v. United States Dept. of Interior D.C. No. 11-5322 (2012)) for

unlawful actions taken by the Council Members as expressed in both the Amended

Complaint and Exhibit 1 thereto. The court must recognize that the sovereign is not the

Tribal Council members as being independent of the people, whether or not in legislative

session, but that the sovereign is the people themselves (Tribe) collectively, who elected the

individual Council members to represent the sovereign (people), respecting their individual

districts that elected them. Said representatives were elected predicated on the basis that they



would conduct the business of the Tribe (sovereign people) within the framework of the body

of laws (Tribal Constitution) that the sovereign (people) have established.

When the system of government functions under a system of separation of powers, such

as the Tribal Constitutional Preamble expresses I, and further expressed by OST Const.

Article III, §}2, and Article IV, §1 and §} (u)3, we discover that the Tribal Council is not

sovereign, but simply has legislative immunity under the sovereign umbrella of the people,

however, limited by and subject to a "Comprehensive Code of Ethics", pursuant OST Const.

Article IV, §l(u). In the year 2008, by and through a "Secretarial Election," governed and

approved by the United States Secretary of Interior, the sovereign (people/Tribe) further

clarified separation of powers by modifying OST Const. ARTICLE V - JUDICIAL

POWERS4, and adding ARTICLE XII - BILL OF RIGHTS5

• The court should take

lOST Const. - PREAMBLE We, the Oglala Sioux Tribe of the Pine Ridge Indian Reservation, in order to establish a more perfect organization, promote the general welfare, conselV'e and develop our lands and resourres, secure to ourselves and our posterity the power to exercise certain ri2hts of home rule not inconsistent with Federal laws and our treaties, and in recognition of God Almighty and His Divine Providence, do ordain and establish this constitution for the Oglala Sioux Tnbe.

2 OST Const. - ARTlCLE III - GOVERN ING BODY

Section 1. The governing body of the Tribe under this constitution shall be a council which shall be composed of councilmen chosen by secret ballot by qualified voters of the tribe, which council shall hereafter be known as "The Oglala Sioux Tribe Council"

3 OST Const. - ARTICLE IV - POWERS OF THE COUNCIL

Section l. Enumerated Powers. The Oglala Sioux Tribal Council shall exercise the following powers; subject to any limitations imposed by the statutes or the Constitution of the United States and subject further to aU express restrictions upon such powers contained in thti Constitution and the attached Bylaws:

(u) To adopt orclinances regulating the procedure of the council itself and of other elected officials of the reservation through a comprehensive code ofethics and removal procedures.

4ARTICLE V - JUDICIAL POWERS

Section 1. Creation. The judicial power of the Oglala Sioux Tribe shall be vested in one Supreme Court and in other inferior tnbal courts established by the Tribal Council. The Supreme Court and other inferior tribal courts shall be independent from the Tribal Council and the Executive Committee, and no elected official exercising powers of the Tribal Council or the Executive Committee shaU exercise powers vested in the Supreme Court or other inferior tribal courts.

Pit's Response In Opposition To (Tribal) Defs' Motion To Dismiss of14


JUDICIAL NOTICE that after elections for a new Council, and prior to taking office and

assuming their duties, as well as enjoying the benefits of "Legislative Immunity," the

Council men/women-elect must each take an oath of office pursuant to OST Const. Article

xv - Oath of Office6 in their non-official capacity. In other words, the Council people-

elect had expressly sworn solemnly to support and defend the Oglala Sioux Tribal

Constitution, and OST Const. Article IV, §J(u) that refers to the "Comprehensive Code of

Ethics" governing/regulating the Council itself, as private individuals.

Because a "Sovereign" cannot sue itself, the "Splitting Doctrine" established under Ex

Parte Young, essentially provides a means of addressing constitutional and criminal

violations conducted or performed by legislators (Council people) acting outside the scope of

their legislative immunity or their duly enacted "Comprehensive Code of Ethics"

governing/regulating the Council itself. It establishes by legal theory, a fictitious litigant (the

Sovereign/Tribe) who otherwise could not be formally named in the law suit against itself.

Such is the case in this matter before the court. Ordinarily, a suit of this type, where

legislators step outside of their legislative authority would be filed against the individual

legislators in their official capacity, rather than in their personal or private capacity, however,

5 OST Const. - ARTICLE XII - BILL OF RIGHTS

The Tribal Council in exercising its inherent powers ofself-governance, shall not make any tnballaw or enforce any triba~ state or federal law that ...

6 OST Const. - ARTICLE XV - OATH OF OFFICE Section 1. Each Tnbal Council Representative and Executive Committee Officer shall be required take an oath of office prior to assuming constitutional duties.

(Oath) I, , do solemnly swear that I will promote, preserve, and strengthen the general health and welfare of the Oglala Lakota Oyate; and I will supPOrt and defend this Constitution and the human rights of the Oglala Lakota Oyate and the human rights ofother peoples as recognized in international laws, treaties - which includes both the 1851 and 1868 Ft. Laramie Treaties, and declarations.



both scenarios exist in this suit. Under the Oglala Sioux Tribal Law & Order Code, Chapter

50 "Oglala Sioux Tribe Revised Code of Ethics" (Ordinance No. 12-10), which is also the

"Comprehensive Code of Ethics" governing/regulating the Council itself in accordance to

OST Const. Article IV, §l(u) . The Council member's alleged constitutional and criminal

violations has been set forth in Exhibit 1, et seq. and incorporated by reference in the

Amended complaint.

Pursuant to the OST Const. Article VIII §1, any council member shall forfeit by

operation of law, his/her office for a conviction of a felony or any other offense of

dishonesty7. Pursuant to the above stated Ethics Code §J(9), procedures for removal shall be

conducted in accordance to OST Ordinance 41-268. According to Ordinance 41-26, each of

the Council members named in this suit have been suspended with pay as of March OS,

20139, and are currently acting unlawfully as a functioning Council "under the Color of Law"

(see service stamp on Exhibit 1). While the named "Tribal Defendants" are lawfully

suspended from their privileges as Council members, said suspension does not in any way

7 OST Const. - ARTICLE VIII - REMOVAL OF OFFICERS

Section 1. Any member or officer of the tribal council who is convicted of a felony or any other offense involving dishonesty shaD forfeit his office.

8 J. (9) .. .Removal or impeachment of any Tribal official shall occur pursuant to Article VIII of the Oglala Sioux Tribe Constitution, Oglala Sioux Tribe Ordinance 41-26, and Oglala Sioux Tribe Resolution 41-90, or any future law of the Oglala Sioux Tribe that governs the process for impeachment of Tribal officials. The procedures provided by Ordinance 41-26 and Resolution 41-90 shall apply to the impeachment of any officer or elected member of the Council as well as any other elected Tribal official to whom this Code of Ethics applies.

9 41-26, ~2 .... A complaint must be signed and sworn to according to law and the accused shall be advised of the charges against him at least (20) days previous to the time set for trial and shall be immediately suspended from his duties upon service of such notice...

' ]3 . Any officer or any member of the Oglala Sioux Tribal Council may be liable to impeachment for crimes, corrupt conduct, gross incompetency, malfeasance or misdemeanor in office . .. The person accused nevertheless shall be liable to indictment, trial judgement and punishment according to law...



abate their obligations in obeying the Ethics Code, nor the Tribal laws. Under the Ethics

Code §D(1)(a) Procedures 10, filing of the EthicslImpeaclunent Complaint (Exhibit 1) was

clearly adhered to. Under the Ethics Code, §E(1) Service upon Respondent" was clearly

adhered to.

At the present, the only lawful Council is the "Executive Committee" that conducts

routine business in between Council sessions pursuant to OST Const. Article XIII, §6 12.

Should any Council person be removed (forfeiture of office) by operation of law, then

according to the OST election ordinance, the next highest vote getter for that respective

office shall fill the vacancy without further costs of a new election.

22. Defendants' argue that there has been no injury to the Plaintiffs, but review of the

Amended Complaint and Exhibit 1 clearly establishes injury and the causal connection

with the defendants, as well as the imminent danger to the Plaintiffs and the Tribe at large.

10 D. Filing a Complaint Any enrolled Tribal member over the age of eighteen (18) years may file an ethics complaint alleging violations of the Oglala Sioux Tribe Code of Ethics against a Tribal official.

I. Procedures a. Ethics complaints must be filed with the Tribal Secretary in writing and signed by the Complainant on a form prescribed by the Ethics Review Board.

11 E. Responding to an Ethics Complaint I. Service Upon Respondent

Within five (5) working days after the complaint has been filed, the Tribal Secretary must either attempt personal service of a copy of the Ethics complaint on the Respondent or send a copy of the ethics Complaint to the Respondent by certified mail, return receipt requested. If personal service is attempted unsuccessfully, the Secretary shall either continue to attempt to have the Respondent personally served until service is successful or send a copy of the complaint by certified mail, return receipt requested.

12 ARTICLE XIII - RESPONSIBILITIES OF EXECUTIVE COMMITTEE OFFICERS

Section 6. There shall be an Executive Committee, which shall consist of the President, the Vice President, the Secretary, the Treasurer, and the Fifth Member. The Executive Committee shall act on behalf of the Tribal Council when the Tribal Council is not in session and shall be in charge of all routine matters that arise during such recess, including the administration of the land provisions of this constitution, and such other matters as may be delegated to it by the Tribal Council, and shall make a report at each Regular and Special session of the Tribal Council, and shall adopt resolutions that are not inconsistent with resolutions or ordinances adopted by the Tribal Council.

Pit's Response In Opposition To (Tribal) Defs' Motion To Dismiss PagelOofl4

Case 5:13-cv-05019-JLV Document 32 Filed 06/05/13 of 14 PageID #: 579

23. Again, Plaintiffs asserts the federal Courts have subject matter jurisdiction:

a. Pursuant 25 USC §1302 (f). rd.

b. The alleged Council Member Defendants' conspiracy was initiated by an

unemployed, tried and convicted by jury, jailed non-member of the Tribal Council,

Bette Goings, and permeated throughout the Council members without reservation,

as clearly expressed throughout Exhibit 1, therefore, the case of Runs After v. United

States, 766 F.2d 347, 352 (8th Cir. 2003) is inapplicable. Additionally, Plaintiffs

alleged violations of 25 USC § l302 (f) (2010) which is federal law, thereby

superseding the precedence of Santa Clara Pueblo (1978). The OST Ethics Code

clearly states that: 6. Preferential Treatment - Officials of the Oglala Sioux Tribe

shall not use or attempt to use their official positions to give preferential

treatment to any private person or organization.

c. On March 11, 20l3, the Council defendants unanimously voted to dismiss the

Ethics/Impeachment Complaint (Exhibit 1) with prejudice and shortly after word

fired the Chief Judge, thereby barring any judicial options available. Even the BIA

Superintendant (Robert Ecoffey) refused to enforce the Tribal Constitution as

evidenced by the Plaintiffs' claims against Mr. Ecoffey. All remedies have been

exhausted, thereby leaving the federal courts the only venue left available. Nor is

there any hope or recourse of a political resolve for criminal violations.

d. Under the Ex Parte Young "Splitting Doctrine", the federal courts may grant

declarative and injunctive relief. (see Vann et al v. United States Dept. of

Interior No. 11-5322 (2012)).

PIt's Response In Opposition To (Tribal) Defs' Motion To Dismiss Page II of 14

Case 5:13-cv-05019-JLV Document 32 Filed 06/05/13 of 14 PageID #: 580

e. Plaintiffs are not challenging the Tribal Constitution, nor Tribal laws, but are seeking

mere enforcement of said laws that where set in place by the sovereign (people),

thereby promoting, preserving and defending Tribal sovereignty.

f. The Federal Government has an overwhelming interest and obligation to protect it's

wards (dependant nations/sovereigns/people) from renegade and despotic Tribal

legislatures that it participated in forming that far outweighs the interests of the

dependant legislatures themselves. When legislatures knowingly and wantonly ignore

the laws it was confined to function within, then said legislatures cease to represent

the people that the people had charged them to represent, and legislative and/or

sovereign immunity is of no avail. Self-determination and government is left to the

people, not a small band of renegades, serving only their private interests at the fate

and expense of the dependant sovereign people (wards).

WHEREFORE, Plaintiffs Patrick A. Lee, Floyd Hand, and William J. Bielecki, Sr., after

discussion with one and another, each respectfully pray upon this Honorable Court to DISMISS

AND STRIKE Tribal defendants' motion entitled "Individual Defendants' Motion To Dismiss",

and deny said named defendants any continuance for filing their answers beyond the required

due date of April 26, 2013. FURTHERMORE, Plaintiffs ask this Honorable Court to grant a

Default Judgment pursuant to Plaintiffs Motion For Default Judgment and Declaratory and

Injunctive Relief for reasons stated above and in their motion for default judgment (see item 27

of docket report). Or in the alternative, grant leave to amend pleadings.

Submitted June 5,2013



By By a~C£e ------------------------

Floyd Hand, Pro Se Patrick A. Lee, Pro Se P.O. Box 150 203 E Oakland St Pine Ridge, SD 57770 Rapid City, SD 57701 (60S) 867-5762 (60S) 341-4360

BYwt2f.~ By

P.O. Box 1990 Pine Ridge, SD 57770 Tel: (60S) 867-5028 Fax: (60S) 867-1006

Pit's Response In Opposition To (Tribal) Defs' Motion To Dismiss ofl4


CERTIFICATION OF SERVICE The undersigned does hereby certify that he/she has duly served a true and correct copy of

the above stated matter (Civ. 13-S019-JLV) and the foregoing Plaintiffs' Response In Opposition To (Tribal) Defendants' Motion To Dismiss And Individual Defendants' Response In Opposition For Default Judgment And Declaratory And Injunctive Relief upon all interested patties and individuals concerned by the below stated method, to wit:

US District Court Clerk Andrew W. Bogue Federal Building and U.S. Coulthouse SIS 9th St, #302, Rapid City, SO 5770 I

Brendan V. Johnson . Esq. Civil Process Clerk U.S. Attorney's Office PO Box 2638 Sioux Falls, SO 57101-2638

[gJ Personal Service, hand delivery D First class U.S. Certified Mail, receipt requested, last known

address D First class U.S. Regular Mail , last known address D Email D Facsimile D Process Server

D Personal Service, hand delivery D First class U.S. Certified Mail, receipt requested, last known

address [8J First class U.S. Regular Mail, last known address D Email D Facsimile D Process Server

Robert Gusinsky, Esq. [8J Personal Service, hand delivery Assistant U.S . Attorney o First class U.S . Certified Mail, receipt requested, last known 515 Ninth St., Suite 201 address Rapid City, SO 5770 I o First class U.S. Regular Mail, last known address

o Email Counsel for BfA D Facsimile

D Process Server

Michael C. Loos, Esq . o Personal Service, hand delivery 2834 Jackson Blvd ., Suite 201 [8J Prepaid First class U.S. Certified Mail , receipt requested, last P.O. Box 9129 known address Rapid City, SO 57709 o Prepaid First class U.S. Regular Mail, last known address

o Email Attorney for Tribal Defendants D Facsimile

o Process Server

Dated June 5, 2013 RESPECTFULLY SUBMITTED

William J. Bielecki , Sr., Pro Se P.O. Box 1990 Pine Ridge, SO 57770 William J. Bielecki, Sr., Pro se Tel: (605) 867-5028 Fax: (605) 867-\006

~



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