April 25, 2019 Memorandum from North to NRA General Counsel and NRA Board Counsel (Exhibit 2 to Counterclaims)
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. Note: while this version of the document has certain redactions, unredacted versions have been filed in other litigations.
- 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.) 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 up a “Crisis Management Committee” with the task of conducting an internal investigation and “addressing and resolving the problems” North identifies in the letter. (Pgs. 6–7.)