Filing Summary

The pleading provides Ackerman’s counterclaims against the NRA for Breach of Contract, Breach of Implied Covenant of Good Faith and Fair Dealing, and Abuse of Process.  It provides a factual overview of the litigation, and the disputes between the parties.  

Key Points

• The pleading includes detailed information about the NRA’s prolific spending with Ackerman.  This includes a May 1, 2019 invoice to the NRA in the amount of $1.69 million and $375,000 to the NRA Foundation.  Ackerman indicates that while the NRA Foundation promptly paid, the NRA did not make payment.  (para.51-52)  
• The May 2019 invoices indicate expenses for “NRATV Programming” of $185,416 for the NRA C4 entity, and $250,000 for the NRA Foundation (a 501(c)(3) entity).  There is no description as to how that split was determined, tracked, and/or audited.
• Further, the May 2019 invoice indicates a $680,355 monthly invoice amount for “Talent Fee”; and another $200,702 for “Support Staff Fee.”  These line items may include costs of NRA TV personalities.  Ackerman also billed the NRA $258,613 in this month for “strategic management.” (para. 52).  Paragraph 63 of the Amended Counterclaim includes additional invoice information. 
• Of note, Ackerman indicates it has been working to locate, catalogue and index NRA property, material, and documents to return to the NRA. A very lengthy list of that property is included as Exhibit D.  Ackerman indicates the contract provides that the NRA must pay charges for the return of such property, and estimates costs of $1.5 million.  (paras 81-84)
• Two paragraphs contain redactions because they reference testimony Wayne LaPierre gave during his deposition. (para 30 and 130)