Memorandum of Law in Support of NRA’s Application
The NRA seeks “expedited relief” to prevent the disclosure of privileged information in the examination of Oliver North. (Pg. 4.) The NRA presents its legal arguments for: (1) why the NRA should be permitted to attend and participate in North’s deposition; and (2) why the North deposition should be suspended until the NRA’s petition is resolved.
- The NRA argues that North has been “privy to substantial attorney-client privileged information” and that this privilege belongs to the NRA and not North. (Pgs. 4–5.) As a result, the NRA claims that it should be allowed to participate in North’s deposition and to lodge objections where it thinks necessary to protect its privilege. (Pg. 5.)
- Both the OAG and North’s counsel agreed to allow the NRA to review the documents North produced in response to the subpoena. (Pg. 5.) The NRA made, by its count, an additional 37 redactions to 899 pages of documents. (Pg. 9.) The NRA also claims that its privilege review revealed a multi-page document that is “wholly privileged.” (Pg. 13.)
- The NRA claims that it and North are “currently adverse,” and so its concerns about the disclosure of privileged information are “heighten[ed].” (Pgs. 12–13.)
- The NRA asks for North’s deposition to be suspended until its petition is resolved. (Pgs. 14–15.)