NRA’s Responses and Objections to UWS’s First Set of Interrogatories
This filing includes the NRA’s responses to UWS’s first set of interrogatories. The NRA objects to nearly every interrogatory and provides only limited information in response to UWS’s questions.
- 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 identify all individuals with relevant knowledge of allegations raised in the complaint. (Pg. 4.) The NRA provides a short list of names, including LaPierre, Carolyn Meadows, Joshua Powell, Tyler Schropp, Pete Brownell, Emily Cummins, Chris DeWittt, John Frazier, Sandra Froman, Wilson Philips, Sonya Rowling, Craig Spray, and Lisa Supernaugh. (Pgs. 5–6.)
- The NRA states that shortly after January 2018, “the NRA began to have concerns about the quality, efficacy, and reach of UWS’s programs.” (Pg. 8.) The NRA’s concerns arose when UWS allegedly “failed to deliver the requisite number of original programs” and “refused to provide basic metrics by which to determine whether UWS was even a remotely successful endeavor.” (Pg. 8.)
- UWS asks the NRA to “list which NRA donors … accompanied NRA executives, officers, and/or board members on UWS hunting trips.” (Pg. 10.) The NRA objects to the request as “burdensome and oppressive,” stating that it would have to “go through hours of footage and log every person who appeared on the UWS program.” (Pg. 10.) Nevertheless, the NRA agrees to “produce documents responsive to this inquiry.” (Pg. 11.)