Free Motion to Amend/Correct - District Court of Federal Claims - federal

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS Sheldon Peters Wolfchild, et al.

Plaintiffs, Vs. United States, Defendant, and Laura Vassar, Christopher Vassar, and Ellen Medicine Horn on Behalf of Lisa A. Vassar. and Tyrel Dryden, Gary L. Moore, Sonja Cook, Sean Moor, Brayden Moore, Aidan Cody, Cook, Ashton Cook, Abigail Cook, Mark Erin Cook, Terrance Vincent Dubray Jr., Michelle DuBray, Leonard Adams, Aspen Alisha Adams, Justin Joseph Adams, Wesley Dean Adams, Darrell W. Watters, Rebecca L. Watters, Brian Nieden, Jr., Richard Wayne Mousseau Jr., Carrie L. Romen, Anthony Chance Hopkins, Jeremiah Arthur Hopkins, Bryan Steven Hopkins Jr., Lewis Crazy Thunder on Behalf of Chaina Michelle Crazy Thunder, Rodney S. Mousseau, Mariah K. Mousseau, Debra Mousseau, Richard Dubray, Francis Good Lance Jr., Arlene Allen on Behalf of John George Waters and Latisha Faye Waters, Kristy Two Bulls, Santana Salway, Kristy Two Bulls Jr., Meldwin Two Bulls, Trisha Elieen Mclaughlin/Two Bulls, Carol Jewel Rouillard, Norene Anne Mousseau, Monet Lare Mills, Shayne Michael Mousseau, Lynden Gorden on Behalf of Hunter Riley and Ryan Patterson, Ulan Trudell, Jane/John Doe, Jane/John Doe, Jane/John Doe,

Case No. 03-2684L Judge Charles F. Lettow

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Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe, Jane/John Doe,

Intervenors.

VASSAR GROUP MOTION TO AMEND COMPLAINT TO ADD AND REMOVE PLAINTIFFS, AMEND THE CAPTION TO REMOVE CERTAIN NAMES AND REMOVE JOHN DOE PLAINTIFFS The Vassar Group mo ve to add and remove certain parties as Intervenors under the United States Court of Federal Claims Rules 20 and 21 and to amend their Complaint in Intervention against the United States under Rule 15(a) to reflect the party changes. The amended complaint does not add any legal claim or legal allegation. The Vassar Group make this motion based on a similar argument as set forth in Plaintiff's Motion to Amend Third Amended Complaint to Add and Remove Certain Named Plaintiffs filed by Plaintiffs Counsel, Mr. Erick G. Kaardal, on January 19, 2007. The changes to the

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caption and identification of proposed additional Plaintiffs are listed on Exhibit A attached hereto and made a part hereof. The Vassar Complaint in Intervention filed by the Moose and Otherday family Plaintiffs was sent Via FedEx on July 11th , 2006. The Complaint in Intervention reached the Clerk of the Court of Federal Claims on July 12th , 2006. The Vassar Complaint is stamped "Received" and filed by Leave of the Judge with the Clerk of the U.S. Court of Federal Claims on July 17th , 2006. All allegations, facts and exhibits attached thereto are hereby incorporated herein by this reference. In Plaintiff's Motion to Amend Third Amended Complaint to Add and Remove Certain Named Plaintiffs filed by Plaintiffs Counsel, Mr. Erick G. Kaardal, on January 19, 2007, Plaintiffs made a motion to incorporate all the Plaintiff/Intervenors currently on the Vassar Complaint in Intervention into Plaintiffs' Fourth Amended Complaint. All of these individuals are siblings and family members of individuals previously designated on Plaintiffs Second Amended Complaint. Counsel for the Vassar Plaintiffs now Motion the Court to amend their pleadings accordingly. If the Court accepts Plaintiff's Motion to Amend Third Amended Complaint to Add and Remove Certain Named Plaintiffs filed by Plaintiffs Counsel, Mr. Erick G. Kaardal, on January 19, 2007, we request those names which will be incorporated into Plaintiffs Fourth Amended Complaint be removed from the Vassar Complaint. Further, Plaintiffs/Intervenors move to add additional Plaintiffs to the Vassar Complaint who are also lineal descendants of an individual who appears on the 1886 Census or the 1889 Supplemental Census. Most of these individuals are siblings,

children or family members of persons named on Plaintiffs' Fourth Amended Complaint.

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These individuals are lineal descendants of Ben Westman, Maggie Campbell, John Frazier, Mary LaBatte, Joseph Moose Senior and Joseph Moose Junior.

Plaintiffs/Intervenors additionally move to add lineal descendants of Elle Turpin who appears on the 1886 Census or the 1889 Supplemental Census. Attorneys for the Vassar Plaintiffs received requests from additional lineal descendants of Joseph Moose Sr. and Lucy Otherday who were unable to secure representation and provide their family documentation prior to the deadline set by this Court. The Plaintiffs listed in Exhibit "A" under Joseph Moose Sr. were living in North Dakota until just recently and did not receive notice of the lawsuit. Upon learning of the lawsuit they attempted to secure representation through the Mohrman & Kaardal and Kettering Law Firms. Several of the Plaintiffs listed on Exhibit "A" under Lucy Otherday were initially represented by the Mohrman & Kaardal and Kettering Law Firms. Due to some delay in securing the appropriate birth records these individuals were not incorporated with their family members on to the Amended Complaint filed by Mohrman & Kaardal and Kettering Law Firms. The Moose and Otherday Plaintiffs were then denied

representation by Mohrman & Kaardal and the Kettering Law Firm. These individuals are family members of individuals who are listed in Plaintiffs Fourth Amended Complaint, as well as those who are listed on Plaintiffs Third Ame nded Complaint filed by Mr. Erick G. Kaardal. These individuals can provide the appropriate documentation, have demonstrated good cause and should be included. The additional Plaintiffs listed on Exhibit "A" under Lucy Otherday live in various parts of the United States and never received notice of the pending litigation.

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These individuals are Peter Martinez, Francisco Martinez Jr., Carol Martinez, Frankie Lee Martinez, Daniel Lane Martinez, Vanessa Lane Martinez, Dustin Lee Martinez, Alex James Martinez, Leroy Martinez, Linda Martinez and John Martinez. These individuals have provided documentation to show they are direct lineal descendants of Lucy Otherday, who is located on the 1886 Census and 1889 Supplemental Census. The above mentioned Otherday Intervenors have demonstrated good cause for admission and should be included. Attorneys for the Vassar Plaintiffs received requests from additional lineal descendants of Joseph Moose Jr. The Plaintiffs listed under Joseph Moose Jr. on Exhibit "A" live in the Santee Nebraska area. These individuals were informed of the pending case before the July deadline. These individuals searched for the documentation to prove their lineage. They were informed by Santee Tribal Officials they "were not entitled and should not file." The Joseph Moose Jr. Plaintiffs attempted to move forward anyway. They were informed they could not receive any documentation through the tribe to show their lineage. Without those documents they were unable to timely prove they were lineal descendants of Joseph Moose Jr. We have now been successful in securing those documents. The Joseph Moose Jr. Plaintiffs have demonstrated good cause and should be admitted. Counsels for Plaintiffs/Intervenors have been working to incorporate the additional Plaintiffs names and family documentation since the initial Complaint in Intervention was filed. The process of incorporating those Plaintiffs who are proper lineal descendants has been time consuming. All additional Moose and Otherday

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Plaintiffs rely on the same arguments as made by individuals already accepted as named Plaintiffs through Mr. Erick G. Kaardal and Plaintiffs Fourth Amended Complaint. Additionally, Counsel has been approached by other potential Plaintiffs who have ancestry similar to persons who are currently named as Plaintiffs through Mr. Erick G. Kaardal and Plaintiffs Fourth Amended Complaint. These individuals are lineal

descendants of Ben Westman, Maggie Campbell, John Frazier and Mary LaBatte who are all listed on the 1886 Census or the 1889 Supplemental Census. The Plaintiffs listed under Ben Westman on Exhibit "A" were initially represented by the Mohrman & Kaardal and Kettering Law Firms. Dustin Alan James believed he would be filed with his family members on Plaintiffs Complaint. He was incarcerated until recently and unable to timely provide the additional documentation the Mohrman & Kaardal and Kettering Law Firms required to be incorporated into Plaintiffs Complaint. Lance Brandt was also incarcerated and could not timely provide the

documentation for himself and his son Kain Brandt. Harper Saul believed she would be filed along with her family members. Due to some questions in the documentation she was rejected by the Mohrman & Kaardal and Kettering Law Firms. She has provided the appropriate documentation. These Plaintiffs have demonstrated good cause and should be admitted. The Plaintiffs listed under Maggie Campbell on Exhibit "A" were initially represented by the Mohrman & Kaardal and Kettering Law Firms. These individuals believed they had the appropriate documentation and would be incorporated with their family members on Plaintiff's Complaint. The Campbell Plaintiffs listed on Exhibit "A" were informed by the Mohrman & Kaardal and Kettering Law Firms the appropriate

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documentation had not been found in time to incorporate them. They were unable to secure alternate representation to timely file. They have been successful in securing the appropriate documentation. The Maggie Campbell Plaintiffs have demonstrated good cause and should be admitted. The Plaintiffs listed under John Frazier on Exhibit "A" were initially represented by the Mohrman & Kaardal and Kettering Law Firms. Due to a name discrepancy, Netawn Marie Kiogima (Graham) was not filed with h family members on Plaintiffs er Complaint and was denied representation. Netawn Marie Kiogima (Graham) has

provided the appropriate documentation. She has demonstrated good cause and should be admitted. Crystal and Robert Dubray believed they would be filed with their family members. provided. They were informed the appropriate documentation had not been timely They were unable to secure alternate representation to timely file. They have

been successful in securing the appropriate documentation. The John Frazier Plaintiffs have demonstrated good cause and should be admitted. The Plaintiff listed under Mary LaBatte on Exhibit "A" is the minor child of Sidney Dean LaBatte, who is named in Plaintiffs Fourth Amended Complaint. Jayceon Blain LaBatte w denied representation by Mohrman & Kaardal and Kettering Law as Firms due to some questions in birth records. He has been successful in securing the appropriate documentation. Jayceon Blain LaBatte has demonstrated good cause and should be admitted. Finally, Counsel has been approached by lineal descendants of Ellen Turpin. These individuals live in the Oregon area. These individuals did not receive any notice of the litigation and finally learned of their claim over the Easter Holiday on April 7th 2007.

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The persons listed on Exhibit "A" under Ellin Turpin have provided documentation to show they are direct lineal descendants of Ellin Turpin who is located on the 1886 Census and 1889 Supplemental Census. The Turpin Intervenors have demonstrated good cause for admission and should be included. With the removal and addition of said individuals, Plaintiffs motion the Court to Amend the Caption and Complaint accordingly. Rule 21 allows for the addition or removal of parties through a motion and order of the court at any stage of an action "on such terms as are just." Rule 20 allows for permissive joinder if "they assert any right to relief jointly, severally, or in the alternative in respect of or arising out of the same transaction, occurrence, or series of transactions, occurrences and if any question of law or fact common to all these persons will arise in the action." The proposed parties meet the requirements of Rules 20 and 21. Further, granting the motion will not prejudice the United States nor cause a delay in the litigation. Courts have allowed the joinder of parties under Rule 20 of beneficiaries in an action against a trustee for breach of fiduciary duty. The addition of certain parties is required because they are trust beneficiaries under the criteria Plaintiffs' established to identify lineal descendants of the May 20, 1886 census and its 1889 supplement, and the law of this case. The additional parties reflect siblings and family members of

individuals already identified as plaintiffs not previously designated and lineal descendants who did not receive notice of the pending lawsuit due to circumstances beyond their control. The Vassar Group requests removal of all John Doe plaintiffs.

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The United States will not be prejudiced with the joinder or removal of the parties. The litigation remains in its adolescence. Despite the court's disposition of one breach of fiduciary duty, there remain outstanding summary judgment motions on legal issues of other identified breaches. No final determination of liability has been made nor final relief determined or sought. Furthermore, there is no scheduling order; no

discovery; and the United States, as trustee, has not identified the specific lineal descendants as trust beneficiaries in light of other Intervenors' theories of assertion of how to determine a trust beneficiary. The addition or removal of certain parties will not put the Plaintiffs/Intervenors in any tactical advantage over the United States. The added parties rely on similar

arguments as set forth in the original Vassar Group Complaint in Intervention which was filed on July 13, 2006 prior to the courts deadline. Each additional Plaintiff is a lineal descendant of an individual who is listed on the 1886 Census or the 1889 Supplemental Census. The additional parties' claims arise out of the same transactions or occurrences as the original Vassar Plaintiffs' claims. The additional parties also claim to sue as

individuals on behalf of themselves and all other descendants of persons listed on the May 20, 1886 Mdewakanton census. Virtually all, if not all, of the legal issues, are common among the additional plaintiffs as are the factual issues. Rule 15(a) states that "a party may amend the party's pleadings only by leave of court or by written consent of the adverse party; and leave shall be freely given when justice so requires." Courts have recognized "[t]he federal rule policy of deciding cases on the basis of the substantive rights involved rather than on technicalities requires that

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[the] plaintiff be given every opportunity to cure a formal defect in his pleadings." Thus, the liberal rule gives effect to the federal policy in favor of resolving cases on their merits instead of disposing of them on technicalities. The addition and removal of certain parties will not prejudice the defendant, is sought in good faith, will not cause undue delay in the litigation, and is not futile for lack of merit and meets the elements of Rule 15(c). The United States is not prejudiced because of the present status of the case; no scheduling order, no discovery, no resolution of pending motions for partial summary judgment on liability, no determination of damages, etc. The United States remains in the same position as before the motion. CONCLUSION The proposed parties are trust beneficiaries and lineal descendants of an individual on the Mdewakanton 1886 census and its 1889 supplement. Their respective and individual identity correspond with the criteria used by the Court--the law of this case. The proposed parties' claims against the United States also relate back to the previously filed Complaint in Intervention and all have common questions of law and fact. The United States will not lose its present position tactically or strategically if the proposed parties are added. Because of the present status of the case, the United States is not prejudiced. Finally, joinder of the proposed parties as plaintiffs will correct minor technicalities and avoid jeopardizing their right of claim as trust beneficiaries against the United States.

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Therefore, the Vassor Group Motion to Add Plaintiffs and Remover Certain John Doe Plaintiffs should be granted and leave granted to file the submitted Amended Complaint to reflect the changes of parties.

Dated this 18th day of April, 2007. /s/Garrett J. Horn Horn Law Office LLC P.O. Box 886 Yankton, SD 57078 (605) 260-4676 Telephone (605) 260-0624 Facsimile Attorney of Record for Intervenors

/s/Creighton A. Thurman Thurman Law Office LLC P.O. Box 897 Yankton, SD 57078 (605) 260-0623 Telephone (605) 260-0624 Facsimile Attorney of Record for Intervenors

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EXHIBIT A Adult and Minor Plaintiff Members Not Previously Designated. Joseph Moose Sr. Henry Albert Meng IV, is the son of Henry Albert Meng Jr. Henry Albert Meng Jr. is the son of Matilda Precilla Moose. Matilda Precilla Moose was the daughter of Stephen Moose. Stephen Moose was the son of Charles Moose. Charles Moose was the son of Joseph Moose Sr. Henry Meng IV, as a descendant of Joseph Moose Sr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Jamie Lee Meng, is the daughter of Henry Albert Meng Jr. Jamie Lee Meng, as a descendant of Joseph Moose Sr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Jessie Marie Meng, is the daughter of Henry Albert Meng Jr. Jessie Marie Meng, as a descendant of Joseph Moose Sr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Lucy Otherday Charity Rose Taylor as a descendent of Lucy Otherday, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Purity Faith Weisz is the minor daughter of Charity Rose Taylor. Purity Faith Weisz as a descendent of Lucy Otherday, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Jessica M.D. Marshall, is the daughter of Roxanne Two Bulls, who is named in Plaintiffs Fourth Amended Complaint. Jessica M.D. Marshall is a lineal descendant of Lucy Otherday. Jessica M.D. Marshall as a lineal descendant of Lucy Otherday, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Teigen Quad O'Rourke is the minor son of Jessica M.D. Marshall. Teigen Quad O'Rourke as a lineal descendant of Lucy Otherday, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Arionna Reece O'Rourke is the minor daughter of Jessica M.D. Marshall. Arionna Reece O'Rourke as a lineal descendant of Lucy Otherday, listed on the 1886 Minne sota Mdewakanton Census, has demonstrated good cause and should be included.

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LouDiamond O'Rourke is the minor child of Jessica M.D. Marshall. LouDiamond O'Rourke as a lineal descendant of Lucy Otherday, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Bobbi Jo Marshall is the child of Roxanne Two Bulls, who is named in Plaintiffs Fourth Amended Complaint. Bobbi Jo Marshall is a lineal descendant of Lucy Otherday. Bobbi Jo Marshall as a lineal descendant of Lucy Otherday, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Manuel Joseph Marshall is the child of Roxanne Two Bulls, who is named in Plaintiffs Fourth Amended Complaint. Manuel Joseph Marshall is a lineal descendant of Lucy Otherday. Manuel Joseph Marshall as a lineal descendant of Lucy Otherday, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Peter (Pedro) Martinez is the son of Edith Marie Martinez (Rouillard), Edith Marie Rouillard is the child of Samuel B. Rouillard Jr., Samuel B. Rouillard Jr. is the son of Samuel Rouillard, Samuel Rouillard is the son of Lucy Otherday who is listed on the 1886 Minnesota Mdewakanton Census. Peter (Pedro) Martinez has demonstrated good cause and should be included. Francisco Martinez Jr. is the son of Edith Marie Martinez (Rouillard). Francisco Martinez Jr. is a lineal descendant of Lucy Otherday. Francisco Martinez Jr. has demonstrated good cause and should be included. Carol Martinez is the daughter of Edith Marie Martinez (Rouillard). Carol Martinez is a lineal descendant of Lucy Otherday. Carol Martinez has demonstrated good cause and should be included. Frankie Lee Martinez is the son of Edith Marie Martinez (Rouillard). Frankie Lee Martinez is a lineal descendant of Lucy Otherday. Frankie Lee Martinez has demonstrated good cause and should be included. Daniel Lane Martinez is a son of Frankie Lee Martinez. Daniel Lane Martinez is a lineal descendant of Lucy Otherday. Daniel Lane Martinez has demonstrated good cause and should be included. Vanessa Lane Martinez is a minor daughter of Daniel Lane Martinez. Vanessa Lane Martinez has demonstrated good cause and should be included. Dustin Lee Martinez is a minor son of Daniel Lane Martinez. Dustin Lee Martinez has demonstrated good cause and should be included. Alex James Martinez is a minor son of Daniel Lane Martinez. Alex James Martinez has demonstrated good cause and should be included.

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Leroy Martinez is the son of Edith Marie Martinez (Rouillard). Leroy Martinez has demonstrated good cause and should be included. Linda Martinez is the daughter of Edith Marie Martinez (Rouillard). Linda Martinez has demonstrated good cause and should be included. John Martinez is the son of Edith Marie Martinez (Rouillard). demonstrated good cause and should be included. Joseph Moose Jr. Ann Marie Roberts (Trudell) is the daughter of Marie Clara Moose. Marie Clara Moose was the daughter of Joseph Moose Jr. Ann Marie Roberts (Trudell) as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Kenneth Joseph Trudell is the son of Marie Clara Moose. Marie Clara Moose was the daughter of Joseph Moose Jr. Kenneth Joseph Trudell as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Rose M. Trudell is the daughter of Kenneth Joseph Trudell. Rose M. Trudell as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Naquia Lee Thomas (Richard) is the daughter of Rose M. Trudell. Naquia Lee Richard as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Rosanna Marie Richard is the daughter of Rose M. Trudell. Rosanna Marie Richard as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Nevaeh Lydia-Grace Richard is the minor daughter of Rosanna Marie Richard. Neveah Lydia-Grace Richard as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Madison Loraine Richard is the minor daughter of Rosanna Marie Richard. Madison Loraine Richard as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Joseph Richard is the minor son of Rosanna Marie Richard. Joseph Richard as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. John Martinez has

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Alexander Richard is the minor son of Rosanna Marie Richard. Alexander Richard as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Daniel Brian Richard is the minor son of Rose M. Trudell. Daniel Brian Richard as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Kenneth William Richard is the minor son of Rose M. Trudell. Kenneth William Richard as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Jeffrey Garnett is the minor son of Rose Marie Trudell. Jeffery Garnett as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Jessie Gene Garnett is the minor son of Rose Marie Trudell. Jessie Gene Garnett as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Cheyenne Bristy Roselee Garnett is the minor daughter of Rose Marie Trudell. Cheyenne Bristy Roselee as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Kiana Taria Garnett is the minor daughter of Rose Marie Trudell. Kiana Taria Garnett as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Naqia Numoon Garnett is the minor daughter of Rose Marie Trudell. Naqia Numoon Richard as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Johnny James Garnett is the minor son of Rose Marie Trudell. Johnny James Garnett as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Jacob Ray Garnett is the minor son of Rose Marie Trudell. Jacob Ray Garnett as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Lucille Ann Case (Trudell) is the daughter of Kenneth Joseph Trudell. Lucille Ann Trudell as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included.

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Rochell Renae Barnes is the daughter of Lucille Ann Case. Rochelle Renae Barnes as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Terrence Lee Case is the minor son of Lucille Ann Case. Terrence Lee Case as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Terry Lee Case is the minor son of Lucille Ann Case. Terry Lee Case as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Tina Marie Trudell is the daughter of Kenneth Joseph Trudell. Tina Marie Trudell as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Mary Louise Reinert (Trudell) is the daughter of Kenneth Joseph Trudell. Mary Louise Trudell as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Timothy Wayne Reinert Jr. is the minor son of Mary Louie Reinert. Timothy Wayne Reinert as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Casey James Reinert is the minor son of Mary Louise Reinert. Casey James Reinert as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Dakota (Cody) James Reinert is the minor son of Mary Louise Reinert. Dakota James Reinert as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Denise Renee Svoboda (Trudell) is the daughter of Kenneth Joseph Trudell. Denise Renee Svoboda as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Todd Allen Svoboda Jr. is the minor son of Denise Renee Svoboda. Todd Allen Svoboda as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Tiffany Amber Svoboda is the minor daughter of Denise Renee Svoboda. Tiffany Amber Svoboda as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included.

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Adam William Svoboda is the minor son of Denise Renee Svoboda. Adam William Svoboda as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Tasha Renee Svoboda is the minor daughter of Denise Renee Svoboda. Tasha Renee Svoboda as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and sho uld be included. Lavina LaVern Trudell Prue is the daughter of Marie Clara Moose. Marie Clara Moose was the daughter of Joseph Moose Jr. Lavina LaVern Trudell Prue as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Ronald Lee Trudell is the son of Lavian LaVern Trudell Prue. Ronald Lee Trudell as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Christopher William Trudell- Wortman is the minor son of Ronald Lee Trudell. Christopher William Trudell- Wortman as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Brandy Marie Trudell-Wortman is the minor daughter of Ronald Lee Trudell. Brandy Marie Trudell-Wortman as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Brandon Tyler Trudell-Wortman is the minor son of Ronald Lee Trudell. Brandon Tyerl Trudell- Wortman as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Reginald Allan Trudell is the son of Lavina LaVern Trudell. Reginald Allan Trudell as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Crystal Clarice Ramirez-Chavez (Allison) is the daughter of Lavina LaVern Trudell Prue. Crystal Clarice Ramirez-Chavez as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Gabriela Jaqueline Harnandez is the minor daughter of Crystal Clarice Ramirez-Chavez. Gabriela Jaqueline Harnandez as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Tomas Patrocinio Alvico-Allison is the minor son of Crystal Clarice Ramirez-Chavez. Tomas Patrocinio Alvico-Allison as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included.

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Lesandro Jose Alvico-Allison is the minor son of Crystal Clarice Ramirez-Chavez. Lesandro Jose Alvico-Allison as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Athena Marie Allison is the daughter of Lavina LaVern Trudell Prue. Athena Marie Allison as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Lysandra M. Nuno-Allison is the minor daughter of Athena Marie Allison. Lysandra M. Nuno-Allison as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Roberta Babcock (Trudell) is the daughter of Lavina LaVern Trudell Prue. Roberta Babcock as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Connie L. Salinas (Babcock) is the daughter of Roberta Babcock. Connie L Salainas as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Maria Eliza Ruiz is the minor daughter of Connie L. Salinas. Maria Eliza Ruiz as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Kelly Ann Babcock is the daughter of Roberta Babcock. Kelly Ann Babcock as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Dillion James Babcock is the minor son of Kelly Ann Babcock. Dillion James Babcock as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Brendalyn Marie Babcock is the minor daughter of Kelly Ann Babcock. Brendalyn Marie Babcock as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Kora Alana Babcock is the minor daughter of Kelly Ann Babcock. Kora Alana Babcock as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Alfred Babcock is the minor son of Kelly Ann Babcock. Alfred Babcock as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included.

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Joseph Babcock is the minor son of Kelly Ann Babcock. Joseph Babcock as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Zoeann Z. McKee (Babcock) is the daughter of Roberta Babcock. Zoeann Zeva McKee as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Sarah Ann Karn is the daughter of Zoeann Z. McKee. Sarah Ann Karn as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Aaron Jacob Letts is the minor son of Sarah Ann Karn. Aaron Jacob Letts as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Alexavier Nathan Karn is the minor son of Sarah Ann Karn. Ale xavier Nathan Karn as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Elizabeth Marie Karn is the daughter of Zoeann Z. McKee. Elizabeth Marie Karn as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Samuel Jason Karn is the son of Zoeann Z. McKee. Samuel Jason Karn as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Rick Leroy Babcock is the son of Roberta Trudell. Rick Leroy Babcock as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Shania Marie Babcock is the minor daughter of Rick Leroy Babcock. Shania Marie Babcock as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Shawn Lee Babcock is the minor son of Rick Leroy Babcock. Shawn Lee Babcock as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Ralph Joseph Babcock is the son of Roberta Babcock. Ralph Joseph Babcock as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included.

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Duane James Babcock is the son of Roberta Babcock. Duane James Babcock as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. William Arthur Babcock is the son of Roberta Babcock. William Arthur Babcock as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Damon J. Picotte is the minor son of William Arthur Babcock. Damon J. Picotte as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Desiree R. Picotte is the minor daughter of William Arthur Babcock. Desiree R. Picotte as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Anthony Simmons Trudell is the son of Marie Clarice Moose. Marie Clara Moose was the daughter of Joseph Moose Jr. Anthony Simmons Trudell as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Shannon Chris Saltzman (Trudell) is the son of Anthony Simmons Trudell. Shannon Chris Saltzman as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Sebastian T. Saltzman is the minor son of Shannon Chris Saltzman. Sebastian T. Saltzman as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Aslia G. Saltzman is the minor daughter of Shannon Chris Saltzman. Aslia G. Saltzman as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Jonathan C. Saltzman is the minor daughter of Shannon Chris Saltzman. Jonathan C. Saltzman as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Melinda Mari Trudell, as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Jennifer Joann Trudell, as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Joe Dakota Trudell, minor child of Jennifer Joann Trudell, as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included.

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Sadee Lee Jade Trudell, minor child of Jennifer Joann Trudell, as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Rose Marie LeadingFighter as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Justin Joseph Adams as a descendent of Joseph Moose Jr., listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Mary LaBatte Jayceon Blain LaBatte, is the minor son of Sidney Dean LaBatte, who is named in Plaintiffs Fourth Amended Complaint. Jayceon Blain LaBatte as a descendant of Mary LaBatte, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Maggie Campbell Rhonda Gay Bellis, daughter of Ronald Bellis, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Brenda Renay Manchego (Bellis), daughter of Ronald Bellis, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Roni Lynn Sherman (Bellis), as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census; daughter of Brenda Renay Bellis; Granddaughter of Ronald Harold Bellis, has demonstrated good cause and should be included. Sesilia Lynn Chavez, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census; minor daughter of Roni Lynn Sherman (Bellis), has demonstrated good cause and should be included. Marcus Silreo Chavez, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census; minor son of Roni Lynn Sherman (Bellis), has demonstrated good cause and should be included. Troy Lee Sherman, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census; minor son of Roni Lynn Sherman (Bellis), has demonstrated good cause and should be included.

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Landon Cole Sherman, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census; minor son of Roni Lynn Sherman (Bellis), has demonstrated good cause and should be included. Juaquin Manchego, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census; daughter of Brenda Renee Manchego (Bellis), has demonstrated good cause and should be included. Megan Celise Manchego, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census; daughter of Brenda Renee Manchego (Bellis), has demonstrated good cause and should be included. Desiree Manchego, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census; minor daughter of Brenda Renee Manchego (Bellis), has demonstrated good cause and should be included. Cory Bren Manchego, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census; minor son of Brenda Renee Manchego (Bellis), has demonstrated good cause and should be included. Juania Maria Manchego, as a descendent of Maggie Campbell, lis ted on the 1886 Minnesota Mdewakanton Census; daughter of Brenda Renee Manchego (Bellis), has demonstrated good cause and should be included. Donovan Tristan Manchego, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census; minor son of Juania Maria Manchego, has demonstrated good cause and should be included. Tayden Dean Esperas, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census; minor son of Juania Maria Manchego, has demonstrated good cause and should be included. Quroeen Manchego, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census; daughter of Brenda Renee Manchego (Bellis), has demonstrated good cause and should be included. Orion Celistiano Clark, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census; minor son of Quroeen Manchego, has demonstrated good cause and should be included. Shi-Matthew Celistiano Sartorio, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census; minor son of Quroeen Manchego, has demonstrated good cause and should be included. Mary March, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included.

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Malia Marquez, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Mateo Marquez, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Anthony C. Marquez, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Kaylee Tucker, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Shanica Tucker, as a descendent of Maggie Campbell, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Benjamin Westman Dustin Alan James is a child of Merle Glen Saul. Merle Glen Saul, who is named in Plaintiffs Fourth Amended Complaint, was the son of Katherine Laverne Redwing (Saul). Katherine Laverne Redwing was the daughter of Thomas Eugene Redwing. Thomas Eugene Redwing was the son of Elizabeth Flute Redwing. Elizabeth Flute Redwing was the daughter of Benjamin Westman who was on the 1886 Census. Dustin was out of touch with his family and unaware of these proceedings until recently. Dustin Alan James has demonstrated good cause and should be included as a plaintiff. Harper Nicole Saul is the daughter of Darrel Dean Saul. Harper Nicole Saul as a descendent of Benjamin Westman, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Lance Albert Brandt (Flying Hawk), as a descendent of Benjamin Westman, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Kain Albert Brandt is the minor son of Lance Albert Brandt (Flying Hawk), as a descendent of Benjamin Westman, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. John Frazier Netawn Marie Kiogima (Graham) is the biological daughter of Larry Graham, who is named in Plaintiffs Fourth Amended Complaint. Larry Graham is a lineal descendant of John Frazier. Netawn Marie Graham was adopted by her stepfather in 1995 and was not informed of these proceedings until very recently. Netawn Marie Kiogima (Graham) has demonstrated good cause and should be included as a plaintiff.

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Crystal DuBray, as a descendent of John Frazier, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Robert DuBray, as a descendent of John Frazier, listed on the 1886 Minnesota Mdewakanton Census, has demonstrated good cause and should be included. Ellin Turpin Franklin Allen LeMay is the son of Leo Oren LeMay. Leo Oren LeMay was the son of Louis Albert LeMay. Louis Albert LeMay was the son of Ellen Turpin who was on the 1886 census. Franklin Allen LeMay has demonstrated good cause and should be included. Eugene Paul LeMay is the son of Leo Oren LeMay. Leo Oren LeMay was the son of Louis Albert LeMay. Louis Albert LeMay was the son of Ellen Turpin who was on the 1886 census. Eugene Paul LeMay has demonstrated good cause and should be included. Nancy Jane Nicklin (LeMay) is the daughter of Eugene Paul LeMay. Nancy Jame Nicklin as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Kari Marika Gusman (Nicklin) is the daughter of Nancy Jane Nicklin. Kari Marika Gusman as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Andrew Monty Nicklin is the son of Nancy Jane Nicklin. Andrew Monty Nicklin as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Zona Kristianna Gusman is the minor daughter of Kari Marika Gusman. Zona Krisitianna Gusman as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Logan Blaze Gusman is the minor son of Kari Marika Gusman. Logan Blaze Gusman as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Tara Jane Corpening (Nicklin) is the daughter of Eugene Paul LeMay. Tara Jane Corpening. as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Aniya Jane Corpening is the minor daughter of Tara Jane Corpening. Aniya Jane Corpening as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included.

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Patrick Eugene LeMay is the son of Eugene Paul LeMay. Patrick Eugene Lemay as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Nathan Eugene LeMay is the son of Patrickk Eugene LeMay. Nathan Eugene LeMay as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Peter Andrew LeMay is the son of Patrick Eugene LeMay. Peter Andrew LeMay as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Noah Peter LeMay is the minor son of Peter Andrew LeMay. Noah Peter LeMay as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Landon Sidney LeMay is the minor son of Peter Andrew LeMay. Landon Sidney LeMay as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Thomas Wayne LeMay is the son of Eugene Paul LeMay. Thomas Wayne LeMay as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Michael Anthony LeMay is the son of Eugene Paul LeMay. Michael Anthony LeMay as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Gregory Andrew LeMay is the minor son of Michael Anthony LeMay. Gregory Andrew LeMay as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Timothy Mark LeMay is the son of Eugene Paul LeMay. Timothy Mark LeMay as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Tina Marie Hoffman (LeMay) is the daughter of Timothy Mark LeMay. Tina Marie Hoffman as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. McKayla Christine Hoffman is the minor daughter of Tina Marie Hoffman. McKayla Christine Hoffman as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included.

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Kelly Marie Hoffman is the minor daughter of Tina Marie Hoffman. Kelly Marie Hoffman as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Brianna Nicole Hoffman is the minor daughter of Tina Marie Hoffman. Brianna Nicole Hoffman as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. John Leo LeMay is the son of Eugene Paul LeMay. John Leo LeMay as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Kathleen Ann Cooper (LeMay) is the daughter of Eugene Paul LeMay. Kathleen Ann Cooper as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Michael De'Aundrey LeMay-Hajarizadeh is the son of Kathleen Ann Cooper. Michael De'Aundrey LeMay-Hajarizadeh as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Cerrissa Jean Elkins is the minor daughter of Kathleen Ann Cooper. Cerrissa Jean Elkins as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included. Amanda Danielle Elkins is the minor daughter of Kathleen Ann Cooper. Amanda Daniell Elkins as a descendent of Ellen Turpin, listed on the 1886 census, has demonstrated good cause and should be included.

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