DOCSLIB.ORG

218 Response

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
218 Response William H. Narwold (pro hac vice) bnarwold@motleyrice.com Mathew P. Jasinski (pro hac vice) mjasinski@motleyrice.com Michael J. Pendell (pro hac vice) mpendell@motleyrice.com Laura W. Ray (pro hac vice) Sarah M. Frazier (pro hac vice) lray@motleyrice.com sfrazier@bafirm.com MOTLEY RICE LLC BERG & ANDROPHY 20 Church St., 17th Floor 3704 Travis St. Hartford, CT 06103 Houston, TX 77002 Tel.: (860) 882-1681 Tel: (713) 529-5622 Fax: (860) 882-1682 Fax: (713) 529-3785 John P. Cashion (Alaska Bar No. 9806025) Charles H. Rabon, Jr. (pro hac vice) john@cashiongilmore.com crabon@usfraudattorneys.com CASHION GILMORE LLC RABON LAW FIRM, PLLC 1007 W. 3rd Ave., Suite 301 225 E. Worthington Ave., Ste. 100 Anchorage, AK 99501 Charlotte, NC 28203 Tel.: (907) 222-7936 Tel.: (704) 247-3247 Fax: (907) 222-7038 Fax: (704) 208-4645 john@cashiongilmore.com Attorneys for Relator Ben Ferris IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ALASKA UNITED STATES OF AMERICA, § Case No. 3:15-cv-00150-HRH ex. rel. BEN FERRIS, § § Plaintiff, § RELATOR’S OPPOSITION § TO DEFENDANTS’ MOTION v. § TO DISMISS THE SECOND § AMENDED COMPLAINT AFOGNAK NATIVE CORPORATION and § PURSUANT TO RULES 12(b)(6) ALUTIIQ, LLC, § AND 9(b) [212] § Defendants. § United States ex rel. Ben Ferris v. Afognak Native Corp, et al.; 3:15-cv-00150-HRH Case 3:15-cv-00150-HRH Document 218 Filed 01/03/17 Page 1 of 37 TABLE OF CONTENTS I. INTRODUCTION .............................................................................................................. 1 II. BACKGROUND ................................................................................................................ 2 A. The Small Business Act’s 8(a) program is reserved exclusively for small business concerns, irrespective of their ownership. .............................................................. 2 B. Relator alleges that Afognak has misrepresented its subsidiaries’ small business status. ...................................................................................................................... 6 C. The only issue before the Court is whether Relator sufficiently has alleged that the misrepresentations were material. ........................................................................... 8 III. LEGAL STANDARD ....................................................................................................... 10 IV. ARGUMENT .................................................................................................................... 11 A. Afognak’s misrepresentations are material because they have “a natural tendency to influence” the payment or receipt of money or property. ................................. 12 1. A reasonable person would attach importance to Afognak’s misrepresentations..................................................................................... 15 2. Even if a reasonable person would not attach importance to Afognak’s misrepresentations, Afognak knew or had reason to know that the government did. ........................................................................................ 17 B. Relator sufficiently has alleged Afognak’s material misrepresentations. ............. 19 1. Relator has alleged a material misrepresentation regarding whether Afognak’s 8(a) subsidiaries are separate and distinct small business concerns. ................................................................................................... 20 2. Relator has alleged a material misrepresentation regarding whether Afognak’s 8(a) subsidiaries do their own work as separate and distinct small business concerns. ........................................................................... 22 3. Relator has alleged a material misrepresentation regarding whether Afognak’s 8(a) subsidiaries are managed as separate and distinct small business concerns. ..................................................................................... 23 4. Relator has alleged a material misrepresentation regarding whether Afognak’s 8(a) subsidiaries pursue growth and development as separate and distinct small business concerns......................................................... 24 C. There is no evidence that the government has actual knowledge of Afognak’s violations. ............................................................................................ 25 V. CONCLUSION ................................................................................................................. 28 United States ex rel. Ben Ferris v. Afognak - i - Native Corp, et al.; 3:15-cv-00150-HRH Case 3:15-cv-00150-HRH Document 218 Filed 01/03/17 Page 2 of 37 TABLE OF AUTHORITIES Cases Ab-Tech Constr. v. United States, 31 Fed. Cl. 429 (Fed. Cl. 1994) ................................................................................................ 18 Am. Elec. Co. v. United States, 270 F. Supp. 689 (D. Haw. 1967) ............................................................................................... 4 Ashcroft v. Iqbal, 556 U.S. 662 (2009) .................................................................................................................. 10 Autodesk, Inc. v. Dassault Systemes Solidworks Corp., No. C 08-04397 WHA, 2008 U.S. Dist. LEXIS 109800 (N.D. Cal. Dec. 18, 2008) ...................................................... 10 Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) .................................................................................................................. 10 Berg v. Honeywell Int’l, Inc., 580 Fed. App’x 559 (9th Cir. 2014) ......................................................................................... 27 Bly-Magee v. California, 236 F.3d 1014 (9th Cir. 2001) .................................................................................................. 11 Ebeid ex rel. United States v. Lungwitz, 616 F.3d 993 (9th Cir. 2010) .............................................................................................. 10, 11 Hooper v. Lockheed Martin Corp., 688 F.3d 1037 (9th Cir. 2012) .................................................................................................. 27 In re Reality Technologies, Inc., SBA No. BDPT-488, 2013 WL 215002 (May 3, 2013) .............................................................................................. 23 In re Sparccom & Assocs., SBA No. BDPT-501, 2013 WL 4502314 (Aug. 19, 2013) .......................................................................................... 25 Livid Holdings Ltd. v. Salomon Smith Barney, Inc., 416 F.3d 940 (9th Cir. 2005) .................................................................................................... 10 Rose v. Stephens Inst., No. 09-cv-05966-PJH, 2016 U.S. Dist. LEXIS 128269 (N.D. Cal. Sept. 20, 2016) ..................................................... 25 Silvas v. E*Trade Mortg. Corp., 514 F.3d 1001 (9th Cir. 2008) .................................................................................................. 10 United States ex rel. Ben Ferris v. Afognak - ii - Native Corp, et al.; 3:15-cv-00150-HRH Case 3:15-cv-00150-HRH Document 218 Filed 01/03/17 Page 3 of 37 United States ex rel. Am. Sys. Consulting v. ManTech Advanced Sys. Int’l, 600 Fed. Appx. 969 (6th Cir. 2015) .......................................................................................... 27 United States ex rel. Handal v. Cent. Empl. Training, No. 2:13-cv-01697-KJM-KJN, 2016 U.S. Dist. LEXIS 105158 (E.D. Cal. Aug. 8, 2016) .................................................. 11, 16 United States ex rel. Harrison v. Westinghouse Savannah River Co., 352 F.3d 908 (4th Cir. 2003) .................................................................................................... 27 United States ex rel. Hendow v. Univ. of Phoenix, 461 F.3d 1166 (9th Cir. 2006) ............................................................................................ 11, 16 United States ex rel. Jordan v. Northrop Grumman Corp., No. CV 95-2985 ABC, 2002 U.S. Dist. LEXIS 26674 (C.D. Cal. Aug. 5, 2002) .......................................................... 28 United States v. Palin, No. 1:14-cr-00023, 2016 U.S. Dist. LEXIS 111225 (W.D. Va. Aug. 22, 2016) ..................................................... 12 United States v. United Healthcare Ins. Co., 832 F.3d 1084 (9th Cir. 2016) ............................................................................................ 10, 11 United States, ex rel. Escobar v. Universal Health Servs., 842 F.3d 103, 2016 U.S. App. LEXIS 21072 (1st Cir. Nov. 22, 2016)............................ passim United States, ex rel. Longhi v. Lithium Power Techs., Inc., 575 F.3d 458 (5th Cir. 2009) .................................................................................................... 12 United States, ex rel. Miller, 840 F.3d 494, 2016 U.S. App. LEXIS 18758 (8th Cir. Oct. 19, 2016) .............................. 14, 16 Universal Health Services, Inc. v. United States, ex rel. Escobar, 136 S. Ct. 1989 (Jun. 16, 2016) ......................................................................................... passim Statutes 15 U.S.C. § 631 ............................................................................................................................... 3 15 U.S.C. § 631(f)(1)(E) ............................................................................................................... 17 15 U.S.C. § 631(f)(2)(C) ............................................................................................................... 17
Load more

Recommended publications
  • Geopolitics and Environment in the Sea Otter Trade
    UC Merced UC Merced Electronic Theses and Dissertations Title Soft gold and the Pacific frontier: geopolitics and environment in the sea otter trade Permalink https://escholarship.org/uc/item/03g4f31t Author Ravalli, Richard John Publication Date 2009 Peer reviewed|Thesis/dissertation eScholarship.org Powered by the California Digital Library University of California 1 Introduction Covering over one-third of the earth‘s surface, the Pacific Basin is one of the richest natural settings known to man. As the globe‘s largest and deepest body of water, it stretches roughly ten thousand miles north to south from the Bering Straight to the Antarctic Circle. Much of its continental rim from Asia to the Americas is marked by coastal mountains and active volcanoes. The Pacific Basin is home to over twenty-five thousand islands, various oceanic temperatures, and a rich assortment of plants and animals. Its human environment over time has produced an influential civilizations stretching from Southeast Asia to the Pre-Columbian Americas.1 An international agreement currently divides the Pacific at the Diomede Islands in the Bering Strait between Russia to the west and the United States to the east. This territorial demarcation symbolizes a broad array of contests and resolutions that have marked the region‘s modern history. Scholars of Pacific history often emphasize the lure of natural bounty for many of the first non-natives who ventured to Pacific waters. In particular, hunting and trading for fur bearing mammals receives a significant amount of attention, perhaps no species receiving more than the sea otter—originally distributed along the coast from northern Japan, the Kuril Islands and the Kamchatka peninsula, east toward the Aleutian Islands and the Alaskan coastline, and south to Baja California.
    [Show full text]
  • Vol33 No3 Fall 2005
    Volume 33, No. 3 Quarterly of the Alaska Historical Society Fall 2005 ALASKA HISTORICAL SOCIETY 2005 CONFERENCE • KODIAK Stepping Stones to History: Islands in Alaska’s Past Kodiak Conference Presentations Schedule Engraving of Three Saints Bay, from a drawing by Luka Thursday, Voronin. For some years, October 6 Kodiak Island was the thru administrative center of the Saturday, Russian American Company, October 8 first at Three Saints Harbor, then at Pavlovsk, the present on page 5 townsite of Kodiak. Alaska and Polar Regions Dept., Elmer E. Rasmuson Library, University of Alaska, Fairbanks. Notes from around the state he Valdez Museum and Historical their work and demonstrating techniques. This Archive’s major exhibition of Quilt & year the program included Athabaskan beadwork T Fiber Expressions this year, “Stitches in and skin sewing, Tlingit beading, and Iñupiaq Time”, has a Manila connection. That’s Manila, carving. Iowa, where member Dorothy Clifton’s grand- mother had completed a quilt top representing The Sitka newspaper continues to feature a the American flag. Seems the end of World War I different artifact from the museum each month. A came and the town had no flag to fly. Quilt to the word with your local paper might be worthwhile. rescue. Over 40 pieces in this 21st annual display demonstrate the evolution of fiber arts from Compiling obituaries may seem a bit morbid, but the traditional to the innovative and are shown they’re invaluable to genealogists and historians. throughout the museum. Even the miner’s cabin The Resurrection Bay Historical Society has has a quilt on the wall.
    [Show full text]
  • Black History in the Last Frontier
    Black History in the Last History Black Frontier Black History Black History in the Last Frontier provides a chronologically written narrative to encompass the history of African Americans in in the Last Frontier Alaska. Following an evocative foreword from activist and community organizer, Ed Wesley, the book begins with a discussion of black involvement in the Paciÿc whaling industry during the middle and late-nineteenth century. It then discusses how the Gold Rush and the World Wars shaped Alaska and brought thousands of black migrants to the territory. °e ÿnal chapters analyze black history in Alaska in our contemporary era. It also presents a series of biographical sketches of notable black men and women who passed through or settled in Alaska and contributed to its politics, culture, and social life. °is book highlights the achievements and contributions of Alaska’s black community, while demonstrating how these women and men have endured racism, fought injustice, and made a life and home for themselves in the forty-ninth state. Indeed, what one then ÿnds in this book is a history not well known, a history of African Americans in the last frontier. Ian C. Hartman / Ed Wesley C. Hartman Ian National Park Service by Ian C. Hartman University of Alaska Anchorage With a Foreword by Ed Wesley Black History in the Last Frontier by Ian C. Hartman With a Foreword by Ed Wesley National Park Service University of Alaska Anchorage 1 Hartman, Ian C. Black History in the Last Frontier ISBN 9780996583787 National Park Service University of Alaska Anchorage HIS056000 History / African American Printed in the United States of America Edited by Kaylene Johnson Design by David Freeman, Anchorage, Alaska.
    [Show full text]
  • Fiscal Year 2011 Cultural Resources Management Program Annual Report for Alaska
    United States Department of the Interior BUREAU OF LAND MANAGEMENT Alaska State Office 222 West Seventh Avenue, #13 Anchorage, Alaska 99513-7599 http://www.ak.blm.gov 8100 (AK-931) Memorandum To: Director (240), LS, Room 204 Attention: Dr. Richard Hanes and Ms. Emily Palus From: Deputy State Director, Division of Resources Subject: Fiscal Year 2011 Cultural Resources Management Program Annual Report This is in response to Washington Office Information Memorandum No. 2011-164, dated July 22, 2011 and released on August 11, 2011, requesting information for the Cultural Resources Management Program annual report. The requested statistical information table is attached. Below are narrative summaries of our Fiscal Year (FY) 2011 accomplishments, though modified, per instruction, to actually cover the period August 1, 2010 to July 31, 2011. They are arranged by the requested headings and are generally annotated to show which Bureau of Land Management (BLM) offices or personnel were involved. Part I: Major FY 2011 Accomplishments associated with the management and protection of archaeological, historical, and paleontological resources and museum collections: #1: Anchorage Field Office (AFO) Outreach and Education Activities during Outdoor Week: The AFO continued its outreach efforts in Alaska’s largest city through various activities. This year’s efforts highlighted the theme of Alaska Archaeology Month: Sharing the Ice Age: Humans and Mammals in Pleistocene Alaska. The AFO archaeologist, with help from BLM Alaska Cultural Program Lead and State Archaeologist Robert King, State of Alaska Office of History and Archaeology archaeologist Richard Vanderhoek, and Joint Base Elmendorf- Richardson archaeologist Karlene Leeper, taught sixth grade students from two school districts about mammoths and prehistoric hunting in Alaska during Outdoor Week in May 2011.
    [Show full text]
  • From the Log-Journal of an Alaskan Orthodox Missionary by Priest Tikhon Shalamov (Kodiak Parish)
    P a g e | 1 Around the Mission: from the Log-Journal of an Alaskan Orthodox Missionary By Priest Tikhon Shalamov (Kodiak Parish) Publishing House of American Orthodox Messenger, New York, 1904 (Translation, notes, and introduction by Dawn Lea Black, MA and Daria Safronova- Simeonoff, MA; edited by Father John Dunlop, D. Min) Father Tikhon Shalamov in 1905 Introduction to Part IIIb [Village of Akhiok to Portage Bay to Three Saints Settlement to Kiliuda Bay Settlement to the Village of Orlovo to Kalsin Bay to Kodiak] For millennia, portaging on Kodiak Island involved carrying light-weight skin boats (baidarkas) from one bay to another in order to either shorten the route or avoid the perils of open-ocean travel. It has been a traditional way for the ancient people of Kodiak to move around the island that had numerous capes and narrow bays. In addition, ocean waters presented considerable danger, especially near the shore because of strong tidal currents and waves. For all the aforementioned reasons, Native Alutiiq people had a well-developed system of portages, three of which are described in this section of the travelogue – Portage Bay to Kaiugnak Bay, Kiliuda Bay to Orlovo, and, finally, Ugak Bay to Kalsin Bay. P a g e | 2 Kodiak Kalsin Orlovo Kiliuda Three Saints Akhiok Portage Bay Shalamov’s 1903 Route on the 1849 Map of Kodiak Island by the Russian American Company: Akhiok to Portage Bay to Kaiugnak Bay, Kaiugnak Bay to Three Saints Settlement to Kiliuda Bay, Kiliuda Bay to Orlovo, Orlovo to Ugak Bay and to Kalsin Bay, Kalsin Bay to Kodiak (St.
    [Show full text]
  • Forge and Falseworks: an Archaeological Investigation of the Russian American Company's Industrial Complex at Colony Ross
    19005 Coast Highway One, Jenner, CA 95450 ■ 707.847.3437 ■ info@fortross.org ■ www.fortross.org Title: Forge and Falseworks: An Archaeological Investigation of the Russian American Company's Industrial Complex at Colony Ross Author(s): James McGhie Allan III Published by: A dissertation submitted in partial satisfaction of the requirements for the degree of Doctor of Philosophy in Anthropology in the GRADUATE DIVISION of the UNIVERSITY OF CALIFORNIA, BERKELEY Source: Fort Ross Conservancy Library URL: www.fortross.org Fort Ross Conservancy (FRC) asks that you acknowledge FRC as the source of the content; if you use material from FRC online, we request that you link directly to the URL provided. If you use the content offline, we ask that you credit the source as follows: “Courtesy of Fort Ross Conservancy, www.fortross.org.” Fort Ross Conservancy, a 501(c)(3) and California State Park cooperating association, connects people to the history and beauty of Fort Ross and Salt Point State Parks. © Fort Ross Conservancy, 19005 Coast Highway One, Jenner, CA 95450, 707-847-3437 Forge and Falseworks: An Archaeological Investigation of the Russian American Company’s Industrial Complex at Colony Ross by James McGhie Allan III B.S. (Saint Mary’s College of California) 1966 M.A. (University of California, Berkeley) 1990 M.A. (East Carolina University) 1997 A dissertation submitted in partial satisfaction of the requirements for the degree of Doctor of Philosophy in Anthropology in the GRADUATE DIVISION of the UNIVERSITY OF CALIFORNIA, BERKELEY Committee in charge: Professor Kent G. Lightfoot, Chair Professor Laurie Wilkie Professor Richard A.
    [Show full text]
  • Risk of Vessel Accidents and Spills in the Aleutian Islands: DESIGNING a COMPREHENSIVE RISK ASSESSMENT
    Risk of Vessel Accidents and Spills in the Aleutian Islands: DESIGNING A COMPREHENSIVE RISK ASSESSMENT The Aleutian Islands, which are intersected by the Northern Pacifi c Great Circle commercial SPECIAL REPORT 293 marine shipping route, are home to natural resources found nowhere else in the world. Unfortunately, oil spills in the Aleutians are not uncommon because of the frequent and sudden storms, high winds, and severe sea conditions to which the region is subject. This report presents a design for a comprehensive risk assessment that would evalu- 293 SPECIAL REPORT ate the risk of vessel accidents and spills in the Aleutians and the potential effectiveness of Risk of Vessel measures to reduce those risks. The report recommends an appropriate framework for the conduct of that assessment. The recommendations identify a logical sequence of discrete steps that can be used to conduct the assessment so that early decisions can be made with regard to the most important safety improvements and risk mitigation options can be Accidents and Spills considered in the order of their priority. Also of Interest Risk of Vessel Accidents and Spills in theRisk of Vessel Aleutian Islands in the Aleutian Islands Polar Icebreakers in a Changing World: An Assessment of U.S. Needs National Research Council, National Academies Press, ISBN 978-0-309-10321-3, 134 pages, 8.5 × 11, paperback, 2007, $33.50 DESIGNING A COMPREHENSIVE Oil Spill Dispersants: Effi cacy and Effects RISK ASSESSMENT National Research Council, National Academies Press, ISBN 978-0-309-09562-4, 400 pages, 6 × 9, paperback, 2005, $55.00 Marine Salvage Capabilities: Responding to Terrorist Attacks in U.S.
    [Show full text]
  • Archaeological Data Recovery at Baranof Castle State Historic Site, Sitka, Alaska: Final Report of Investigations (ADOT&PF Project No
    Archaeological Data Recovery at Baranof Castle State Historic Site, Sitka, Alaska: Final Report of Investigations (ADOT&PF Project No. 71817/TEA-000-3[43]) J. David McMahan, editor Contributions by: Daniel Thompson Margan Allyn Grover Renee Petruzelli Timothy (Ty) L. Dilliplane Michael W. Strunk March 2002 Office of History and Archaeology Division of Parks and Outdoor Recreation Alaska Department of Natural Resources 550 W. 7th Avenue, Suite 1310 Anchorage, Alaska 99501 OFFICE OF HISTORY AND ARCHAEOLOGY REPORT NUMBER 84 i ACKNOWLEDGEMENTS An overwhelming number of organizations and individuals contributed to the success of the Castle Hill Archaeological Project. The Alaska Department of Transportation and Public Facilities (ADOT&PF) and the Federal Highway Administration (FHA) funded the archaeological recovery program. The contractor, John McGraw, cooperated in the recovery effort and assisted at every opportunity. Mount Edgecumbe High School in Sitka generously allowed the use of a well-equipped science laboratory for artifact processing in conjunction with the field recovery effort. The Sitka Campus of the University of Alaska Southeast provided low-cost university housing near the site in exchange for student field-school opportunities. Other organizations that assisted with the project include: the Alaska Historical Commission; the Alaska Historical Society; Alaska Magazine (Andy Hall); Alaska Southeasterner magazine; the Alaska State Museum (Brook Bowman, Jan Criswell, Steve Henrikson); Alaska State Parks, Sitka office (Ranger
    [Show full text]
  • Number 67 Draft: Not for Citation Without Permission
    DRAFT: NOT FOR CITATION WITHOUT PERMISSION OF AUTHOR NUMBER 67 THE RUSSIAN-AMERICAN COMPANY AND THE IMPERIAL GOVERNMENT By Mary E. Wheeler North Carolina State University Kennan Institute for Advanced Russian Studies Woodrow Wilson International Center for Scholars ' • t ' r... : THE RUSSIAN-A.tVERICAN CO!vlPANY AND THE H1PERIAL GOVERN:v!E!l'!' The creation of the Russian-~~erican Company and its relationship to the Imperial Govern:.;ent need to be reassessed. Soviet scholars have maintained that the formation of the Russian-American Company and the granting to it of a b7enty- year mono?oly was a conscious attempt by the government to create a mighty monopolistic company, under direct government control to strengthen and expand Russia's hold in the North Pacific and to counter foreign expansion in this area. 1 On the other hand, I ~1ave held that the Russian-&uerican Com?any grew naturally out of the practices of the Russian merchants engaged in the Pacific fur trade and was the posthumous creation of the "astute and far­ sighted" Grigorii Ivanovich Shelikhov. 2· I vmuld li]c.e to suggest that both these views may well be incorrect; that the com?any vas established only to bring order out of the chaos brought about by merchant rivalry in Irkutsk following the death of Shelikhov, and that the grant of privileges for twenty rs was not the conscious creation of a strong monopoly for ria lis tic purposes but an attempt to broaden--rather than limit--merchant partici?ation in the North Pacific fur trade. These are only tentative conclusions based on a reexamination of the events leading to the formation of the Russian-American Company and further study is needed.
    [Show full text]
  • The Fleet of the Russian-American Company Evguenia Anichtchenko Anchorage Museum, 625 C Street, Anchorage, AK 99501; Janichenko@Anchoragemuseum.Org
    the fleet of the russian-american company Evguenia Anichtchenko Anchorage Museum, 625 C Street, Anchorage, AK 99501; janichenko@anchoragemuseum.org abstract From the first fur-hunting expeditions in the middle of the eighteenth century until the sale of Alaska in 1867, the success of Russian colonization in Alaska depended on the colonial fleet. Ships brought the first explorers and settlers across the ocean, delivered supplies and people from the motherland, defended the coast, and carried on trade and commerce. Yet to date there has been no study specifi- cally focused on the fleet of the Russian-American Company. This article fills this gap by discussing the formation of the company’s fleet as a dynamic process within the context of a wide array of com- mercial, political, and social issues. introduction In many instances Russian colonialism followed the typi- cal pattern of colonial settlements—almost all of which cal pattern of European expansion, but several aspects were located on the coast—and thus determined the made “Russia’s adventure in America” unique. Russia extent of Russian contact with different Alaska Native joined the European exploration of the New World rela- groups as well as the colony’s ability to access and exploit tively late. Russian Alaska was the country’s first and only different natural resources. Yet to date there has been overseas colony. Moreover, it was the Russian Empire’s no study specifically focused on the fleet of the Russian- first attempt at establishing a sociopolitical organization of American Company (RAC), although some aspects of it almost exclusively maritime character.
    [Show full text]
  • Alaska Native Brotherhood & Alaska Native Sisterhood in Southeast Alaska
    The History of the Alaska Native Brotherhood & Alaska Native Sisterhood in Southeast Alaska 1 Geography of Alaska 2 Alaska Native Groups 3 The ANB & ANS Began in Sitka, Alaska in 1912 The Alaska Native Brotherhood Hall was built in 1914 on the waterfront in Sitka. It is now a national historic landmark. ANB Hall 4 The Founding Fathers of the Alaska Native Brotherhood - Peter Simpson, Tsimshian Canadian (“Father of ANB”) Rise of the ANB - Ralph Young, Sitka - Chester Worthington, Wrangell - James C. Johnson, Klawock - Paul Liberty, Sitka - Seward Kunz, Juneau - Frank Mercer, Juneau - Frank Price, Sitka - George Field, Klawock - Eli Katanook, Angoon - James Watson, Juneau - William Hobson, Angoon - Andrew Wanamaker, Sitka ANB & ANS Constitution Preamble The purpose of this organization shall be to assist and encourage the Native in his advancement from his Native state to his place among the cultivated races of the world, to oppose, to discourage, and to overcome the narrow injustices of race prejudice, to commemorate the fine qualities of the Native races of North America, to preserve their history, lore, art and virtues, to cultivate the morality, education, commerce, and civil government of Alaska, to improve individual and municipal health and laboring conditions, and to create a true respect in Natives and in other persons with whom they deal for the letter and spirit of the Declaration Independence and the Constitution and laws of the United States. 6 The Alaska Native Sisterhood - Promoting Alaska Native Women’s Rights since 1926 Panel Discusses Alaska Native Sisterhood Elizabeth Peratrovich - Alaska Native Sisterhood Grand President and Civil Rights Leader 7 ANB & ANS Political and Cultural Leaders William Paul (1885-1977) - An attorney, legislator, and political activist from the Tlingit nation of Southeastern Alaska.
    [Show full text]
  • The Russian Orthodox Mission in Alaska and the Centrality of Cosmology Niklaus Von Houck Nikla@Uw.Edu
    University of Washington Tacoma UW Tacoma Digital Commons History Undergraduate Theses History Winter 3-8-2019 Creating an Indigenous Multicultural Faith: The Russian Orthodox Mission in Alaska and the Centrality of Cosmology Niklaus von Houck nikla@uw.edu Follow this and additional works at: https://digitalcommons.tacoma.uw.edu/history_theses Part of the Anthropological Linguistics and Sociolinguistics Commons, Comparative Methodologies and Theories Commons, Comparative Philosophy Commons, Critical and Cultural Studies Commons, Cultural History Commons, Eastern European Studies Commons, History of Religion Commons, Indigenous Studies Commons, Intellectual History Commons, Liturgy and Worship Commons, Metaphysics Commons, Missions and World Christianity Commons, Nature and Society Relations Commons, Religious Thought, Theology and Philosophy of Religion Commons, Social and Cultural Anthropology Commons, and the Sociology of Religion Commons Recommended Citation von Houck, Niklaus, "Creating an Indigenous Multicultural Faith: The Russian Orthodox Mission in Alaska and the Centrality of Cosmology" (2019). History Undergraduate Theses. 40. https://digitalcommons.tacoma.uw.edu/history_theses/40 This Undergraduate Thesis is brought to you for free and open access by the History at UW Tacoma Digital Commons. It has been accepted for inclusion in History Undergraduate Theses by an authorized administrator of UW Tacoma Digital Commons. Creating an Indigenous Multicultural Faith: The Russian Orthodox Mission in Alaska and the Centrality of Cosmology
    [Show full text]