Filing Summary

This filing includes the NRA’s responses to UWS’s request for admissions. The NRA objects to or denies nearly every request for admission.

Key Points

• The NRA first lists a number of general objections including objections to any requests seeking documents that are privileged as well as objections to any requests that are overbroad, vague, or require documents outside the NRA’s custody. (Paras. 1–15.)
• UWS asks the NRA to admit that “Wayne LaPierre, Pete Brownell, and Carolyn Meadows had the authority to enter into binding contracts on behalf of the NRA.” (Pg. 5.) The NRA objects to the request as “vague” and “overbroad.” (Pg. 5.)
• The NRA admits that it “failed to make the September 1, 2019 payment to UWS in the amount of $250,000” that UWS alleges was due under the Sponsorship Agreement. (Pg. 6.) The NRA similarly stated that it did not pay a $300,000 payment UWS alleges was due under the Advertising Agreement. (Pg. 6.)
• The NRA admits that “Wayne LaPierre and other NRA executives participated in safaris paid for by UWS to extol the benefits of hunting and/or promote the NRA brand.” (Pg. 6–7.)
• UWS asks the NRA to admit that “UWS paid for Wayne LaPierre’s and Susan LaPierre’s hunting trophies while he was Executive Vice President of the NRA.” (Pg. 7.) The NRA objects, claiming that “‘hunting trophies’ is vague” and on relevance grounds. (Pg. 7.)
• UWS asks the NRA to admit that: (1) “in 2016, Wayne LaPierre, while President of the NRA, and Susan LaPierre attended an elephant hunt for UWS in Bostwanna [sic],” (Pg. 7); (2) LaPierre “shot and attempted to kill[] an elephant,” (Pg. 8); and (3) LaPierre “ordered Tony Makris not to air the footage from the elephant hunt,” (Pg. 8). The NRA objects, claiming that “‘an elephant hunt’ is vague” and on relevance grounds. (Pgs. 7–8.) UWS also asks the NRA to admit that LaPierre “knew this would leave UWS with insufficient footage to complete the show.” (Pg. 8.) The NRA objects on vagueness and relevance grounds. (Pg. 9.)
• UWS asks the NRA to admit that “LaPierre, as Executive Vice President of the NRA, requested UWS to cancel, or cut-short, one or more hunting trips to assist the NRA with Second Amendment strategy as a result of nationally recognized shootings.” (Pg. 9.) The NRA denies the allegation. (Pg. 9.)
• UWS asks the NRA to admit that the Agreements “do not require documentation or production of information sufficient to show total viewership, on an episode by episode basis, of the show.” (Pg. 10.) The NRA denies the allegation. (Pg. 10.)
• UWS asks the NRA to admit that LaPierre “appeared on UWS to appease his critics that his reputation was weak in the hunting community.” (Pg. 11.) The NRA states that it “lacks knowledge sufficient to admit or deny this request.” (Pg. 11.)
• UWS asks the NRA to admit that the Agreements are “for a set dollar amount and do not require NRA approval of expenses or disbursement.” (Pg. 11.) The NRA denies the allegation. (Pg. 11.)
• UWS asks the NRA to admit that LaPierre “possessed full mental capacity at the time of execution of the Agreements.” (Pg. 12.) The NRA states only that it “incorporates its General Objections.” (Pg. 12.)