This filing is similar to the initial complaint filed August 6, 2019, with the exception being the amended complaint asserts new claims (RICO and mail fraud) against the Defendants based on the same factual allegations included in the original complaint.
- Dell’Aquila is a “longtime donor and supporter of the NRA.” (Para. 7.) Previously, he had pledged to give 75% of his estate to the NRA upon his death and has given “approximately $100,000” to the NRA and the NRA Foundation over the last four years. (Para. 7.) He brought this class action lawsuit alleging “fraud in the solicitation of donations” by LaPierre, the NRA, and the NRA Foundation. (Para. 6.)
- Dell’Aquila alleges that the Defendants spent “significant portions of donated funds for purposes unrelated to the NRA’s core mission.” (Para. 13.)
- According to Dell’Aquila, when the Defendants solicited donations, they told potential donors that funds “would be used for gun safety education; to promote shooting sports and hunter safety; to foster wildlife conservation; and to protect gun ownership rights in the United States.” (Paras. 42, 49.) Dell’Aquila describes these goals as the NRA’s “core mission.” (Para. 42, 52.) He claims these solicitations were false because the NRA and NRA Foundation used solicited funds for alternative purposes. (Paras. 45, 52.)
- Dell’Aquila alleges that the NRA used solicited funds for alternative purposes, including: (1) “spending over $97,000 per day for the legal services of William A. Brewer … without obtaining documentation justifying such expense”; (2) “spending $274,695 for clothing purchases for … LaPierre from a Beverly Hills clothing store, without reporting such expenses as income for LaPierre”; (3) “spending $243,644 on luxury travel for … LaPierre to the Bahamas [and other destinations] without reporting such compensation as income for LaPierre”; (4) “making inflated payments to the NRA’s advertising agency, Ackerman …, without obtaining documentation justifying such expense”; (5) “spending $5,446.16 per month for a luxury apartment for Megan Allen, an intern”; (6) “spending funds for a board meeting for the NRA, to be held in Alaska, rather than in Fairfax”; and (7) by “paying … LaPierre an annual salary of $1.4 million.” (Para. 45.)
- Dell’Aquila alleges that the NRA Foundation used solicited funds for alternative purposes, including: (1) transferring approximately $80 million from the NRA Foundation (a tax-deductible charitable organization) to the NRA which then used those funds for the alternative purposes described above; (2) “paying $425,000 per year for nine years to the Speedway Children’s Charity, a non-profit organization not related to the NRA’s core mission”; and (3) “paying at least $125,000 to Youth for Tomorrow, a non-profit organization not related to the NRA’s core mission” that included LaPierre’s wife, Susan, on its board for five years. (Para. 52.)