Filing Summary

This document is a letter from UWS counsel to NRA counsel attacking the objections raised by the NRA in response to UWS’s discovery requests.

Key Points

• UWS complains that the NRA has “made blanket objections to all of the discovery requests … even the most basic of requests, such as questions about who is answering the interrogatories.” (Pg. 1.) UWS points out that the question of who is answering the interrogatories “is the most basic of interrogatory requests that is included in almost every set of interrogatories issued” and thus the NRA’s objection is in “bad faith,” particularly as “the person answering the interrogatories is required to sign the answers under oath.” (Pg. 2.)
• UWS claims that the NRA “failed to produce a single document” in response to UWS’s requests. (Pg. 4.)
• UWS notes that the NRA incorrectly referred to UWS as the “Defendants,” stating “[p]erhaps your staff should be more careful in its cut and paste of boilerplate objections from other litigation pending by or against the NRA.” (Pg. 4.)
• UWS complains that the NRA objected to a question asking for information about “binding contracts” on vagueness grounds. (Pg. 6.) UWS states: “As I would hope you would be aware, a ‘binding contract’ is a legally enforceable agreement between two or more parties.” (Pg. 6.)
• UWS rejects NRA objections based on lack of knowledge, noting the NRA is under a duty to make a reasonable inquiry. (Pg. 6.) As to one interrogatory asking about whether UWS paid for LaPierre’s hunting trophies, UWS notes “LaPierre is an NRA executive and simply asking him this question would yield a response.” (Pg. 6.)
• UWS also complains about the NRA’s claim that “an elephant hunt” is vague. (Pg. 6.) UWS states that “there is no ‘hiding the ball’ here, it is exactly what it says it is, a hunt for elephant.” (Pg. 6.)
• UWS notes that the facts surrounding LaPierre’s elephant hunt with UWS are relevant to this lawsuit because UWS claims that it “did not produce the requisite number of shows … because Wayne LaPierre and Susan LaPierre did not want certain footage aired.” (Pg. 6.)