Ackerman’s Memorandum in Support of Ackerman’s Motion to Compel the NRA to Produce Documents
Ackerman asks the Court to order the NRA to provide more information during the discovery process. Perhaps most interestingly from a factual perspective, the filing references several segments of deposition testimony from the litigation and also attaches the NRA’s interrogatory responses.
- LaPierre testified the Brewer firm did a lot of work for the NRA, “including dealing with folks inside that were declaring themselves as whistleblowers. Somebody had to go and run down all of those and find out whether there was any truth in it or not and then run down each one of those.” Yet, Ackerman claims the NRA has failed to produce any documents about the “whistleblowers” at the NRA. (p.2-3)
- Please note this filing contains a number of exhibits that could be of interest.
- Exhibit B (p.63-75): Ackerman Attorney Letter, 10/29/2019 (contains discussion and excerpts of several NRA depositions, including Wayne LaPierre’s). The letter notes that LaPierre, in his deposition, identified Gayle Stanford as “the individual who arranged travel and hotel accomodations for NRA personnel, including him.” Further, the letter indicates that Craig Spray, in his deposition, “specifically named McKenna & Associates and Mike Marcellin” as those “not meeting compliance standards”, and apparently also said “I can’t name them all necessarily off the top of my head right now… but there are numerous.”
- Exhibit D (p.99-141): NRA’s responses to Ackerman’s Interrogatories.
- In Interrogatory #1, the NRA lists the following NRA employees/board members as those with knowledge relevant to the case: Andrew Arulandandam, Dan Boren, Emily Cummins, Michael Erstling, John Frazer, Millie Hallow, Steve Hart, Wayne LaPierre, Oliver North, Portia Padilla, Joshua Powell, Duane Reno, Sonya Rowling, Craig Spray, and Rick Tedrick. Further, the NRA identifies the following Ackerman employees: Angus McQueen, Revan McQueen, Melanie Montgomery, Nader Tavangar, and Bill Winkler.
- In Interrogatory #10, the NRA states that “former counsel to the NRA Board of Directors, Steven J Hart, conspired with [Ackerman]” to distribute information damaging to the NRA to key NRA board members. It also lists Oliver North as a “co-conspirator.”
- In Interrogatory #17, the NRA notes that “the NRA is aware that Tyler Schropp, a former Ackerman employee who began work with the NRA in or about 2010, continued to submit expense reimbursements through Ackerman until 2018.”