I. The Tapes

A.1. Chronological Summary of the Tapes

Brief summaries of the conversations on the tapes

A.2. Exerpts from the Tapes

Excerpts of relevant material from the tapes

A.3. Tape 1 - Transcript of Conversations on February 8, 2000

Chief Thompson Discusses Concerns Over PPE Strategy

B. Tape 2 - Transcript of Conversations on February 8, 2000

Cummis and Horn: Discussion of Mohawk Relations and Matters of Mutual Concern to PPE and Presidents

C. Tape 3 - Transcript of Conversations on February 11

Thompson & Horn: Discuss PPE Proposal for Assistance, Horn & McDonald: Concern About Trigger Proposed for Loan Repayment Tied to Proceeding with Raceway Project

D. Tape 4 - Transcript of Conversations on February 17-27, 2000

2-16 Kaufman & Cummis: Success of PPE Mtg with Mohawks, PPE indemnification, Payroll “squeeze”; 2-17 Horn & Cummis: Issues Surface in Negotiations; 2-24 Horn & Cummis: Mohawks Concerned about Akwesasne; 2-27 Horn & Cummis(2): Negotiations and Strategy

E. Tape 5 - Transcript of Conversations on February 29, 2000

1)Horn and Cummis Negotiate arrangement btw PPE and President RC; 2)Horn and Thompson: Discussion of mutual concerns; 3) & 4)Horn & Kaufman attempt to reach Cummis; 5) Thompson and Kaufman: status of negotiations 6) & 7) Reaching Cummis

F. Tape 6 - Transcript of conversatons in March and April, 2000

3/13:-Cummis & Kaufman: Contract Negotiations; 3/15 - Horn & Cummis: Cummis, 'taking care of' NY and Washington, presses revised structure; Cummis, Kaufman & Horn: discuss language; 4/4 - Kaufman & Cummis: differences aired;

G. Tape 7 - Transcript of Conversations in April 2000

April 13 – Cummis & Horn: Cummis describes final terms with Mohawks, Real Interest is Monticello; Several Days Later – Horn, Thompson, and other Chiefs – Licenses have suddenly been revoked.

H. Memo Supporting 60b Motion to Vacate Judgment

Plaintiffs Memorandum of Law Supporting Motion to vacate original Judgment

I. Plaintiffs Memo of Law submitted after discovery

Memo of law covering additional materials resulting from discovery after judgment was vacated

J. Defendant Reply Memo on 60b Motion

Park Place Response concerning motion to vacate judgment

K. Correspondence re Tapes

Correspondence to Park Place Attorneys regarding tapes

L. Plaintiffs Reply

Reply Memorandum regarding new evidence after decision vacated

N. Sanctions Letter and Scribbled Response of Judge McMahon

The only form of response by Judge McMahon to request for sanctions