The Counties respectfully request that the Court dismiss the action filed by The Mishewal Wappo Tribe of Alexander Valley (“Plaintiff”) pursuant to Fed. R. Civ. P. 12(b)(1), 12(b)(6), and 12(h)(3). Plaintiff alleges that the Secretary of the Interior’s 1959 termination of the Mishewal Wappo Tribe of Alexander Valley did not comply with the California Rancheria Act (Pub. L. No. 85-671, 72 Stat. 619), a Congressional act authorizing the termination of the Mishewal Wappo Tribe and forty other specifically enumerated California rancherias. Am. Compl. at 3, ¶ 5; 4, ¶ 12; 23, ¶ 77; 30, ¶ 110. More than five decades after the fact, Plaintiff now asks the Court to reverse the 1959 termination, bypass Congress’s exclusive authority over tribal recognition matters, and direct that Plaintiff be given immediate federal recognition, all available public lands within Plaintiff’s “historically aboriginal land,” and the right to conduct casino-style gaming on such “restored lands.”