Case 2:17-cv-00321-DN Document 45 Filed 10/10/17 Page 1 of 5 Richita Hackford Pro se 820 East 300 North 113-10 Roosevelt, Utah 84066 Cell Phone (435) 724-1236 UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION ZJll GCT I 0 t.:> 3: 3 (1 BY:[) i~t:yt~y~j=r:if~~- - - GRANT CHARLES, in his official capacity as Attorney for Roosevelt City, Utah, v. Plaintiff, UTE INDIAN TRIBE OF THE UINT AH and OURAY RESERVATION, BUSINESS COMMITTEE FOR THE UTE TRIBE OF THE UINTAH and OURAY RESERVATION; TRIBAL COURT FOR THE UTE TRIBE OF THE UINTAH and OURAY RESERVATION; WILLIAM L. REYNOLDS in his official capacity as Chief Judge of the Ute Tribal Court; and RICHITA HACKFORD, OPPOSITION TO REPLY IN SUPPORT OF MOTION TO DISMISS Case No. 2:17-cv-00321-DN Judge David Nuffer Defendants. Defendant "Hackford" is in "Opposition" to the Ute Tribal attorney's "Reply in Support of Motion to Dismiss" as being used only as an attempt to unlawfully and illegally "escape" their part and knowing participation as legal representatives' involved in the State of Utah's 'fraud' surrounding the "Ute tribe" of unincorporated State Ute citizens. Any attempt for the Ute tribe attorneys to file a "Motion to Dismiss as Moot" in the near future, again is viewed by the defendant "Hackford" as an attempted act of continued fraud before the court. Defendant "Hackford" is legally protected under Executive Order 1861 and Congressional Act May 5, 1864 for the Uinta Valley Shoshone Tribe, Shoshone Uinta Valley Reservation (not a state Ute reservation) by federal Indian law and Congressional Acts. Any attempts to "Dismiss" 1
Case 2:17-cv-00321-DN Document 45 Filed 10/10/17 Page 2 of 5 before the court now is a federal violation of the defendant "Hack:fords" tribal/federal/ congressional/constitutional and civil rights legally protected under the 1934 IRA-Indian Reorganization Act as a member of the Uinta Valley Shoshone Tribe of Affiliated Ute Citizens, Shoshone Uinta Valley and Ouray Reservation. The "the tribe" of state Ute citizens legal representatives and or attorneys' are before the court under the defendant "Hackford's" filing in "the tribe/state Ute citizens/ tribal court" and by Plaintiff Grant Charles filing in this court against "the tribe" defendants and "Hackford" a named defendant the root and sole cause for said filing in this court by Plaintiff Grant Charles. That is now before the court under defendant "Hackford' s" verifiable claims of a long outstanding fraud by the State of Utah, state licensed attorneys' involving the states usage of the 'state Ute citizens' of which "the tribe" is a primary and legally "pertinent" state actor now involved before the court under acts of continued fraud, for the court to even remotely entertain a dismissal of the case before the court under continued acts being fraudulent presented before a federal court by both parties involved herein (Plaintiff Grant Charles and the "Ute tribe, the tribe") would be a legal injustice to the federal Indian defendant "Hackford" causing a continuation of the 'long suffering' and 'harm' by the continuance of the 'state actors' herein violating "Hackford's" tribal/federal/congressional/constitutional and civil rights. This case must continue forward defendant "Hackford" ask the United States to 'legally enjoin' in this case as the United States uninformed absence risk duplicative litigation as a direct result of the United States "uninformed absence". The "United States is an Indispensable Party to be Enjoined" before the court. This case is an issue of 'fraud' wherein the United States definitely retains the primary legal interest in responding to both state parties herein, as to the fraudulent allegations being presented before the court by Plaintiff Grant Charles, and the 2
Case 2:17-cv-00321-DN Document 45 Filed 10/10/17 Page 3 of 5 collective Utah state citizens as "the tribe" both parties claims before the court are so 'outlandish' as being unlawfully promoted within the federally recognized Shoshone Uinta Valley and Ouray Reservation boundaries a federally recognized Shoshone Indian Reservation under the State ofutah's allegations that most definitely has involved the BIA-Bureau oflndian Affairs a U.S. government agency by supporting and promoting the State of Utah's state Ute citizens "Ute tribe" as a "federal tribe". The United States most assuredly must enjoin to protect the United States "interest" as the United States has the primary interest, in defeating none Indian 'state actors' under the BIA- Bureau of Indians as a 'federally recognized Ute tribe" before the court. Therefore "Hackford" request the United States to be enjoin in this case. Dated this day October 6, 2017 JiJJz~,.ti~ cl Richita Hackford 820 E 300 N 113-10 Roosevelt, UT 84066 Cell# (435) 724-1236 3
Case 2:17-cv-00321-DN Document 45 Filed 10/10/17 Page 4 of 5 Certificate of Service I, Richita Hacl("ford hereby certify that on October 6, 2017, I did by U.S. Postal Service, Mail a copy of my "Opposition to Reply in Support of Motion to Dismiss" to the following: Judge David Nuffer United States District Court District ofutah, Central Division Office of the Clerk United States Courthouse 351 South West Temple Salt Lake City, Utah 84101 1 original with signature and 1 copy page 1 to be stamped filed & returned in pre~ paid self-addressed envelope. J. Preston Stieff ( 4 7 64) J. Preston Stieff Law Offices 11 0 South Regent Street, Suite 200 Salt Lake City, Utah 84111 and to JeffreyS. Rasmussen (Pro Hac Vice) Alvina L. Earnhart (Pro Hac Vice) FREDERICKS PEEBLES & MORGAN, LLP 1900 Plaza Drive Loiosville, CO 80027 Ute Indian Tribe Business Committee Chairman Luke Duncan PO Box 190 Fort Duchesne, Utah 84026 Ute Indian Tribal Court Chief Judge William Reynolds PO Box 190 Fort Duchesne, Utah 84026 Terry L. Pechota Federal Circuit Judge Pechota Law Office 1617 Sheridan Lake Rd Rapid City, South Dakota 57702 Continues next page 4
Case 2:17-cv-00321-DN Document 45 Filed 10/10/17 Page 5 of 5 Jesse C. Trentadue (#4961) Britton R. Butterfield ( # 1315 8) Suitter Axland, PLLC 8 East Broadway, Suite 200 Salt Lake City, Utah 84111 Grant Charles c/o Suitter Axland, PLLC Roosevelt City Attorney 255 South State Street Roosevelt, Utah 84066 United States Department of Justice Tracy Toulou, Director Office of Tribal Justice Room 2318, RFK Main Justice Building 950 Pennsylvania Avenue, N.W. Washington, D.C. 20530-001 United States Department of Justice US Attorney General, Jeff Sessions 950 Pennsylvania Avenue N.W. Washington, D.C. 20530-001 5