Free Motion to Dismiss - Rule 12(b)(1) - District Court of Federal Claims - federal

Case 1:06-cv-00943-LMB

Document 18-14

Filed 08/23/2007

Page 1 of 2

DEFENDANT'S EXHIBIT 13

Case 1:06-cv-00943-LMB

Document 18-14

Filed 08/23/2007

Page 2 of 2

THE SALT RIVER .PIMA-MAR!COPA INDIAN¯ CO MMUNITY, Ptainliff

U.S. COURT OF FEDERAL CLAIMS

943 L
THE UNITED STATES,

Oefendant.
COMPLAINT FOR DAMAGES FOR BREACH OF TRUST OBLIGATIONS
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GENERAL NATURE OF THE ACTION

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This action is an action for money damages against the United States; brought to
" " {" O. redress gross breaches of tr'-st by °h,.. United States, acting by and through' Dlrk Kemp,~home,

Secretary of the Interior ("Kempthorne), Ross Swimmer, Special Trustee for American indians ("Swimmer"), and Henry M. Paulson, Secretary of the Treasury ("Paulson"), and their predecessors in office and subordinates, as trustees and trustee-delegates of land, mineral resources and other assets held by them for the benefit of the Salt River Pima-Madcopa Indian Community ("Community"). As set forth more fully below, this case arises out of Defendant's continuing material breaches of statutory, regulatory, and fiduciary duties owed to the Comm unity and the Community seeks damages lbr Defendant's mismanagement of the Community's trust property. It.
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THE PARTIES

Plaintiff is a federally recognized Indian tribe with nearly 6,000 enrolled It members, located in Arizona. is the beneficiary of reaI property and the proceeds therefrom,

SR00286