Filing Summary

This filing contains NRA’s response to Ackerman’s Motion to Compel documents and includes various defenses of the speed and scope of its document production during the course of discovery.  Of interest, the filing attaches the NRA’s interrogatory responses.  

Key Points

• The NRA claims to have produced 28,000 documents to Ackerman in the course of the case, with additional productions forthcoming. (p.2)
• “The NRA produced several of Wayne LaPierre’s responsive notepads on January 21, 2020, and expects to produce additional handwritten notes from him within the next two weeks.” (p.5)
• Exhibit A (starting at page 16 of the PDF) includes the NRA’s responses to Interrogatories issues by Ackerman. 
• In Interrogatory #1, the NRA lists the following NRA employees/board members as those with knowledge relevant to the case: Andrew Arulandandam, Dan Boren, Emily Cummins, Michael Erstling, John Frazer, Millie Hallow, Steve Hart, Wayne LaPierre, Oliver North, Portia Padilla, Joshua Powell, Duane Reno, Sonya Rowling, Craig Spray, and Rick Tedrick.  Further, the NRA identifies the following Ackerman employees: Angus McQueen, Revan McQueen, Melanie Montgomery, Nader Tavangar, and Bill Winkler.
• In Interrogatory #10, the NRA states that “former counsel to the NRA Board of Directors, Steven J Hart, conspired with [Ackerman]” to distribute information damaging to the NRA to key NRA board members.  It also lists Oliver North as a “co-conspirator.”
• In Interrogatory #17, the NRA notes that “the NRA is aware that Tyler Schropp, a former Ackerman employee who began work with the NRA in or about 2010, continued to submit expense reimbursements through Ackerman until 2018.”
• Further, the NRA claims that Ackerman is yet to produce documents from key executives Revan McQueen, Melanie Montgomery, and William Winkler. (p.3)