Filing Summary

This brief contains the NRA’s arguments seeking expedited document discovery from Ackerman McQueen. 

Key Points

• The parties appear to dispute the relevant time period for document discovery, with Ackerman McQueen seeking to produce documents from 2018 onwards, but the NRA seeking a longer period (2015 to present).  (p.5-8 of the brief)
• The parties disagree as to the relevance of a purported other client/project of Ackerman – Clear Skies TV.  At page 12-13 of the brief, the NRA argues that information about this endeavor goes to Ackerman’s knowledge about the NRATV, or as the NRA’s complaint alleges, Ackerman and the other defendants “had reason to know that even its most conservative projections for NRATV were fanciful.”
• The NRA alleges that Ackerman and the individual defendants viewed Oliver North as “an insurance contract” against the NRA.  “This is because [Ackerman] facilitated giving North a lucrative agreement to film feature development for NRATV that [Ackerman] enabled him not to perform, in effect giving him large sums of money for nothing.”  The brief further alleges “this insurance contract was effectively triggered when, with their backs against the wall, Defendants used North in connection with a (failed) coup of the NRA.” (p.14)
• The NRA also tells the Court that it should award sanctions against the defendants for “extreme discovery malfeasance.” (p.17)