Filing Summary

This filing contains the NRA’s objections to the discovery requests made by UWS.

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.)
• Among the requests the NRA is fighting, UWS requests that the NRA produce documents relating to Tony Makris, television production, advertising, or hunting trips from January 1, 2016 to the present. (Pg. 6.)
• Additionally, UWS requests that the NRA produce “the applications, payments, and related documents of Wayne LaPierre and Susan LaPierre into the Shikar Safari Club International.” (Pg. 8.)
• UWS asks the NRA to produce “the deposition transcript of Wayne LaPierre in the matter of National Rifle Association of America v. Ackerman McQueen, CL19001757.” (Pg. 9.) The NRA objects to this request as irrelevant. (Pg. 9.) The NRA also objects on the grounds that it is prohibited under a protective order from disclosing some deposition transcripts that are designated as confidential. (Pgs. 9–10.)
• UWS asks the NRA to produce “any and all photographs, images, or likenesses from Botswana, Africa involving any NRA officer, director, or donor.” (Pg. 10.) The NRA objects to the extent it requires the NRA to gather “publicly available documents.” (Pg. 10.) The NRA also objects on relevance grounds, but agrees to produce “nonobjectionable, responsive documents.” (Pg. 10.)