its immunity to counterclaims, including compulsory ones. Potawatomi, 498 U.S. at 509, 111 S.Ct. 905; see also United States v. U.S. Fid. & Guar. Co., 309 U.S. 506, 513, 60 S.Ct. 653, 84 L.Ed. 894 (1940) (“Possessing [ ] immunity from direct suit, we are of the opinion [that a tribe] possesses a similar immunity from cross-suits.”); McClendon, 885 F.2d at 630 (“[W]e consistently have held that a tribe’s participation in litigation does not constitute consent to counterclaims asserted by the defendants in those actions.”). And we have held that a tribe’s voluntary participation in administrative-proceedings does not waive its immunity in a subsequent court action filed by another party seeking review of the agency proceedings. See Kescoli v. Babbitt, 101 F.3d 1304, 1310 (9th Cir. 1996) (<HOLDING>); Quileute Indian Tribe v. Babbitt, 18 F.3d
holding that tribes voluntary participation in administrative proceedings is not the express and unequivocal waiver of tribal immunity that we require in this circuit holding that the waiver of sovereign immunity must be clear and unequivocal holding that a state may waive its sovereign immunity holding that a tribes agent who has apparent authority may waive immunity without board approval holding that tribes did not waive their immunity by intervening in  administrative proceedings because any waiver must be unequivocal and may not be implied