NRA’s Memorandum of Law to Compel Supplemental Answers to Interrogatories
The NRA asks the Court to order Ackerman to provide more information during the discovery process, including more detailed answers to pre-trial interrogatories. The exhibits to the brief contain factual information of note. The NRA also asks the Court to sanction the attorneys for Ackerman McQueen.
- Exhibit B (p.65 – 93) contains Ackerman’s Interrogatory Responses (Second Set), dated 9/10/2019.
- Interrogatory #7-9 includes a list of 24 witnesses Ackerman claims have knowledge relevant to its counterclaims, along with a description of the person’s relevant knowledge. These individuals include: Revan McQueen, Melanie Montgomery, Lacey Duffy Cremer, Bill Winkler, Branddon Winkler, John Popp, Tony Markis, Nader Tavangar, Oliver North, Dana Loesch, Wayne LaPierre, Andrew Arulanandam, Emily Cummins, Millie Hallow, Steve Hart, Craig Spray, Tyler Schropp, Rick Tedrick, Travis Carter, Josh Powell, Lisa Supernaugh, Wilson Phillips, Forensic Risk Alliance, and William Brewer.
- Interrogatory #12 indicates that Ackerman was approached by “representatives of Congress and representatives of the New York Attorney General Office concerning investigations of the NRA.” (p.78)
- Exhibit D (p. 98-109) contains a discovery letter to the NRA from counsel for Ackerman. Of note, the letter attaches a four page chart (p.106-109) of all Ackerman employees – over 250 individuals – who worked on the NRA account from 2015-2018.