Filing Summary

This filing is Oliver North’s answer to the NRA complaint. North denies most of the factual allegations that the NRA makes against him and asserts a counterclaim seeking a judgment that he is entitled to indemnification from the NRA for his legal fees. North makes several allegations against the NRA, mostly relating to retaliatory actions taken by LaPierre and Brewer to prevent any investigation of their conduct.

Key Points

• North focuses his arguments on the language of the NRA’s Bylaws: “Each Director shall be entitled to indemnification and expenses immediately to the fullest extent requested in writing … unless and only unless prohibited by corporate laws of the state.” (Pg. 2, Para 2.)
• After North became president of the NRA, he learned of “allegations of potential financial misconduct.” (Pg. 2, Para. 4.) First, North learned the NRA was paying its outside counsel, Brewer Attorneys & Counselors about $2 million a month, under LaPierre’s “improper[]” authorization. (Pg. 2, Para. 5.) Second, North learned of allegations in The New Yorker about the mismanagement of NRA funds. (Pg. 2, Para. 6.) And third, North learned of allegations that LaPierre had received “hundreds of thousands of dollars in clothing, private jet travel, and other personal benefits that were paid for by an NRA vendor.” (Pg. 3, Para. 7.)
• According to the filing, North “pressed to engage outside professionals to conduct an internal investigation into the allegations to determine the facts and to advise the NRA.” (Pg. 3, Para. 8.) North wrote the General Counsel of the NRA on April 18, 2019 to explain his concerns about payments to the Brewer firm. (Pg. 3, Para. 9.) He asked that the NRA conduct an outside, independent review of the payments. (Pg. 3, Para. 9) North also wrote to the Executive Committee of the NRA board on April 25, 2019 to form a “Crisis Management Committee” in response to allegations of financial misconduct in the NRA. (Pg. 3, Para. 10.)
• According to North, each time he raised concerns about misconduct, “North’s efforts were thwarted by LaPierre and Brewer. No investigations were started. The Crisis Management Committee was shut down.” (Pg. 4, Para. 11.)
• North alleges that LaPierre and Brewer engaged in a retaliatory campaign against him and cites several examples. (Pg. 4, Para. 12.) First, LaPierre blocked North’s re-nomination as President of the NRA on April 24, 2019. (Pg. 4, Para. 14.) North was president of the NRA for only eight months. (Pg. 4, Para. 14.) Second, LaPierre “defam[ed]” North in a public letter circulated to the NRA board on April 25, 2019. (Pg. 5, Para. 15.) That letter “falsely alleged that North had tried to engage in a ‘coup’ to get [LaPierre] to step down.” (Pg. 5, Para. 15.) North claims that he was a “long-term, close personal friend of LaPierre,” and never sought his removal. (Pg. 5, Para. 15.) Third, on May 13, 2019, LaPierre sent North a letter denying him indemnification for his legal fees. (Pg. 5, Para. 16.) Fourth, on May 31, 2019, North tried “to force [North] to resign from the NRA [b]oard.” (Pg. 5, Para. 17.) North refused. (Pg. 6, Para. 17.) Fifth, on June 19, 2019, LaPierre sued North in this lawsuit “requiring him to engage in litigation with its attendant costs, including legal fees and expenses.” (Pg. 6, Para. 18.) North suggests that this lawsuit was brought to “further advance the fictitious ‘coup’ story,” which North claims LaPierre and Brewer planted in the press. (Pg. 6, Para. 18.) Sixth, on June 25, 2019, LaPierre “caused the NRA to breach its contract with Ackerman, which produced North’s show on NRATV.” (Pg. 6, Para. 19.) As a result, Ackerman was “unable to pay North” under the contract. (Pg. 6, Para. 19.)
• According to North, LaPierre and Brewer took retaliatory action against others, including the NRA board’s lawyer, who forwarded materials regarding the allegations against LaPierre to the NRA’s Audit Committee. (Pg. 7, Para. 21.)
• North suggests that the NRA brought this suit in New York instead of Virginia, where the NRA is headquartered, because “Brewer was recently thrown out of a Virginia court for making a false statement.” (Pg. 7, Para. 22.) Brewer’s pro hac admission to the Eastern District of Virginia was revoked after the court learned that “Brewer had failed to disclose … that a Texas State Court judge had disciplined Brewer for acting unethically.” (Pg. 7, Para. 22.)
• North states that “the lawsuit that Brewer is leading against Ackerman … appears to be motivated by Brewer’s long-simmering animosity toward his current in-laws, who run Ackerman.” (Pg. 10, Para. 12.)