Filing Summary

Exhibit 10(b): This exhibit is a letter written by Oliver North to the Executive Committee of the NRA. It addresses a “crisis” within the NRA “affect[ing the NRA’s] ability to operate as a nonprofit organization.” He points to allegations in the media of financial mismanagement, the lawsuit against Ackerman, allegations with respect to LaPierre’s expenses, and enormous fees paid to outside counsel as evidence of crisis. He sets up a “Crisis Management Committee” to conduct an internal investigation of the NRA.

Exhibit 10(c): 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.

Key Points

• North states that the “NRA faces a crisis that could affect its ability to operate as a nonprofit organization.” (Pg. 5.)
• He points to articles in The New Yorker, The Wall Street Journal, and The New York Times that allege mismanagement of nonprofit funds. (Pg. 5.)
• He claims that the NRA’s lawsuit against Ackerman in Virginia was “filed without consultation and without informing members of the NRA Board of Directors or key officers of the NRA,” and calls it a “public airing of what might be an internal dispute.” (Pg. 5.)
• He also states that after Ackerman sent letters about LaPierre’s spending, LaPierre fired NRA board counsel Steve Hart without consulting the board. (Pg. 6.) North states that after Hart was fired, Hart sent the Ackerman letters to the NRA Audit Committee with messages that the board has a fiduciary duty to inquire further into the letters. (Pg. 6.)
• North claims that for two months, he and others have urged LaPierre to conduct an “independent, outside review of the substantial payments that the NRA has been making to Brewer Attorneys & Counselors,” exceeding $24 million. (Pg. 6.)
• North purports to set us a “Crisis Management Committee” with the task of “addressing and resolving the problems” North identifies in the letter to conduct an internal investigation. (Pgs. 6–7). 

• North states that the NRA paid $24 million to Brewer Attorneys & Counselors over a 13-month period. $5 million of that amount was “apparently … reimbursed in connection with the Lockton Settlement.” (Pg. 9)
• North indicates that he asked NRA management for two months to retain outside counsel to review the payments made to the Brewer firm to no avail. 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 that the Brewer firm fees require review, including that the fees are “excessive on their face,” up to $97,787 per day every day for Q1 2019. (Pg. 10.).  North claims the NRA has gone out of its way to avoid examination of these fees. (Pg. 11.)
• North notes William Brewer’s disciplinary history as an attorney, namely that he 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.) Those sanctions 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.)