Filing Summary

This exhibit is a letter in which Oliver North asks the NRA General Counsel and Chairman of the NRA Audit Committee to review the fees paid to Brewer Attorneys & Counselors. North states that the Brewer firm was paid $24 million over a 13-month period. North claims that the NRA has fought efforts to investigate these fees and points out that William Brewer has been sanctioned in Texas and ejected from NRA litigation in Virginia.  Note: while this version of the document has certain redactions, unredacted versions have been filed in other litigations.

Key Points

• North states that the NRA paid $24 million to the Brewer firm over a 13-month period. (Pg. 9.) Five million dollars of that amount was “apparently … reimbursed in connection with the Lockton Settlement.” (Pg. 9)
• North indicates that he spent two months asking NRA management to retain outside counsel to review the payments made to the Brewer firm, to no avail. (Pg. 9.) He also notes that board counsel has “urged” the NRA to engage a “well-respected ethics lawyer” to perform an independent examination to ensure the NRA complies with New York’s not-for-profit laws. (Pg. 9.)
• North identifies several reasons why the Brewer firm fees require review, including: (1) the fees are “excessive on their face,” up to $97,787 per day every day for Q1 2019, (Pg. 10); (2) the NRA has gone out of its way to avoid examination of these fees, (Pg. 11); (3) the Brewer engagement letter is “inconsistent with industry standards” primarily because (a) it is “vague regarding the scope of work Brewer is performing for the NRA,” (b) it requires the NRA to pay corporate rates even though it is a not-for-profit, and (c) it includes a surcharge for in-house charges for support services, (Pgs. 12–13); (4) the NRA’s oversight of the Brewer firm is “totally inconsistent with industry standards” because the NRA has failed to require the Brewer firm to adhere to billing guidelines or to charge rates appropriate for not-for-profits and the type of work Brewer performs for the NRA, (Pg. 13); and (5) William Brewer has been found by a Virginia federal district court to have misled the court by failing to disclose a prior disciplinary finding in Texas that resulted in sanctions for Brewer, (Pgs. 14–15). The sanctions against Brewer were upheld by the Texas Court of Appeals. (Pg. 15.)  As a consequence of Brewer’s failure to disclose this history, the Virginia court removed him from a case for the NRA. (Pg. 14.)
• North stresses that the NRA board must act in its fiduciary duty to ensure the NRA “responsibly uses the funds it raises from members and the public.” (Pg. 17.)