Here it is, online. [For older posts, click “blog” in top menu]
The footnote on pages 1-2 is funny. “In addition, Mr. LaPierre denies that “The National Rifle Association of America, Inc.”, named in the caption as the lead Defendant and referred to repeatedly throughout the Complaint, actually exists, and objects to the use of the name “The National Rifle Association of America, Inc.” in the Complaint on the grounds that it is fictitious, creates confusion, and has made it difficult to respond to the Complaint.” The point is that NRA doesn’t have the word “Inc” after its name but to pretend this is confusing and makes it hard to respond to the allegations is worth a laugh.
Almost all of it is “denies on information and belief,” which means “it’s true, I can’t really deny it, but I don’t want to admit it and get flattened without a fight.” There are a few tidbits.
Para 143 to 152, “between June 2016 and February 2018, the organization paid for certain flights for his wife and extended family that were related to National Rifle Association of America business when he was not a passenger, that he admitted that he authorized some of these flights, that the flights were not approved for security reasons, and that the flights were not approved by the National Rifle Association of America Board.” “admits that, in August 2016, he authorized a private flight for his niece and her husband to fly from Dallas, TX, to North Platte, NE so that his niece could attend a National Rifle Association of America Women’s Leadership Forum meeting. . . .” “admits that, in July 2017, he authorized a private flight for his niece and her daughter to fly from Dallas, TX, to Orlando, FL” “admits that, in October 2016, he authorized a private flight for his wife to fly alone from Madison, WI, to Kearney, NE” “admits that in January 2017, he authorized a private jet to pick up his niece’s husband in North Platte, NE, on the way to Las Vegas for a Safari Club convention, that he authorized a private flight to fly his niece’s husband back to Nebraska” “admits that, on occasion, he has directed chartered aircraft to stop in Nebraska to pick up or drop off family members forthe purpose of facilitating work on National Rifle Association of America Women’s Leadership Foundation business” “admits that, in November 2018, he and his wife took a private roundtrip flight from Washington D.C. to Dallas, TX, and stopped in North Platte, NE, on each leg of the trip to pick up and drop off his niece and grandniece so that he, his wife and his niece could work together onNational Rifle Association of America Women’s Leadership Foundation business.”
There are a lot more trips listed, but you get the flavor. Private leased jets, at around $7,000 per flight hour and maybe more, shuttling his family around and NRA members paying for it. For no better reason than it was more convenient than waiting in an airport. Para 154, “admits that, in February 2018, he authorized a private flight for an NRA spokesperson, her husband, and an employee of a vendor.”
Para 159, “admits that, since June 2015, he and his family have taken private flights to and from the Bahamas on occasion and that on some of those trips, he stopped in Nebraska on each leg of the trip to pick up and drop off his niece and her family.” And had NRA pick up the tab for these vacations.
Para 165, “National Rifle Association of America partnered with ATI from 1997 to 2019 to produce and distribute a television series called Crime Strike, that for most of its run, Crime Strike was hosted by him. . . .” NRA paid millions, over 22 years, to produce a TV series that no one ever saw. Paid to a company whose CEO gave LaPierre the use of his yacht in the Bahamas.
Para 167, “admits that he has frequently met with the MMP Principal, that he took private flights to California on many occasions between late 2013 and early 2017—usually staying at a hotel in Beverly Hills—to meet with the MMP Principal and others, often over lunch or dinner, and that, between 2013 and 2016, the MMP Principal, his wife, and their daughter received gifts from the National Rifle Association of America.” I guess the millions paid them were not enough.
Para 168, “admits that has attended “celebrity retreats” organized by the MMP Principal, that when he has attended these retreats, which were held annually in the Bahamas in December, that he stayed at the Atlantis resort on Paradise Island, and that his lodging was paid for by the MMP Principal”
Para 169, “admits that he has often visited the Bahamas in the summer, that during these trips, he would stay on a yacht owned by the MMP Principal, that the yacht named Illusions was equipped with four staterooms and two jet skis, with a crew that included a chef”
Para 170, “admits that he has never disclosed his use of the boat in the Bahamas on the National Rifle Association of America Financial Disclosure Questionnaires that he, as an officer and ex officiodirector of the National Rifle Association of America, has submitted to the National Rifle Association of America Secretary annually, and that Question 4 of that questionnaire asked: ‘Have you or any relative received, or do you or any relative expect to receive, any gift, gratuity, personal favor, or entertainment with either a retail price or fair market value in excess of $250 from any person or entity that has or is seeking to have a business relationship with, or received funds from, NRA or any NRA Entity?'”
Para 170, “admits that he answered no to this question in every questionnaire he submitted from 2008 to 2018 (the most recent questionnaire produced by the National Rifle Association of America to the Attorney General).”
Para 178, “admits that since being elected Executive Vice President, he has not used the National RifleAssociation of America’s regular travel agent to make his travel arrangements, that, since the 1990s, he has booked travel through a travel consultant based in Woodland Hills, CA, and that the travel consultant bills the National Rifle Association of America through two companies: Inventive Incentive & Insurance Services Inc. and GS2 Enterprises (collectively, the “Travel Consultant”),”
Para 193, “admits that, in May 2017, his wife was appointed to the Board of Directors of the National Park Service Foundation (NPSF), and that, over the next few months, he submitted expense reports requesting expense reimbursements for trips taken with his wife to NPSF events in Alaska and Arizona, and that this was in addition to the expense of the flights used to get them to the NPSF events.” So when she went to the Park events, he went with her and passed the tab onto NRA. They probably flew by leased jet, and didn’t submit that bill to the Park Foundation because they’d gag and ask do you really expect us to pay this?
Para 194, “admits that he has submitted expense reports seeking reimbursements for his niece’slodging and airfare for events related to National Rifle Association of America business, and that he submitted reimbursement requests for his niece’s travel expenses on occasion, and that, in 2016 and 2017, the National Rifle Association of America reimbursed certain expenses for his niece’s airfare and lodging.”
Para 195, “in 2013, he was reimbursed by the National Rifle Association of America for airfare, lodging, and related expenses that he and his wife incurred travelling to Botswana for an Under Wild Skies film shoot on safari, representing the National Rifle Association of America and its Women’s Leadership Forum, for the purpose of building the National Rifle Association of America’s brand and developing relationships between the National Rifle Association of America and hunters and donors.” NRA paid for his safari.
Para 196, “admits that, between 2009 and 2017, he expensed membership fees for a golf club located in the Washington D.C. area,”
Para 207, “admits that he gave videotaped testimony about an armored vehicle”
Para 208 & 209, “the co-founder of Ackerman proposed having a real-estate investment company that he owned purchase a house that he and his wife could use as a safe house from time to time,” “admits that he and his wife as a safe house from time to time.”
Para 243, about his Chief of Staff, “when Powell first joined theNational Rifle Association of America in June 2016, Powell’s salary was set at $250,000, that it was later retroactively increased to $500,000” Retroactively? Salary doubled in 2-3 years?
Para 252, about Powell sending NRA a check to reimburse improper expenses, “Powell sent the National Rifle Association of America a check in that amount, which the National Rifle Association of America declined to deposit.” Huh?
Para 274, about the legal experience of the man he appointed General Counsel of the NRA, “Frazer left the National Rifle Association of America to work in private practice in 2013 and that, in January 2015, Frazer returned to the National Rifle Association of America full-time as General Counsel”. Para 275, “admits that, at the time of his appointment as Secretary and his designation as General Counsel, Frazer had been licensed as an attorney for seven years, and had been in private practice in his own firm for 18 months.”
Para 330, “admits that, as part of his work for the National Rifle Association of America and as part of his wife’s work for the National Rifle Association of America Women’s Leadership Foundation, he and his wife appeared in episodes of Under Wild Skies, traveling to and participating in big game hunts in the United States, Botswana, Tanzania, South Africa, and Argentina, and that the expenses associated with these trips— including professional hunter costs, camps, chartered travel, food and beverages, hunting licenses, trophy fees, and taxidermy—were incurred by UWS as part of the show, and lacks knowledge or information sufficient to form a belief as to the truth of the allegation that “[a]ccording to the president of Mercury Group and UWS, a single game hunt of this nature could cost upwards of $100,000”.”
Para 339, “admits that, in 2016, he authorized Powell to terminate the then Executive Director of theNational Rifle Association of America’s General Operations who had been in that role from 2012 to 2016, and that, upon information and belief, National Rifle Association of America security personnel publicly escorted him out of the building.” And thereafter agreed to pay him a lot of “hush money.”
Para 393, “admits, upon information and belief, that the National Rifle Association of America has a current Board member who is a past National Rifle Association of America President and who has been paid under the EVP Consulting Budget since 2004, and that, on behalf of the National Rifle Association of America, he has signed contracts with the Board member.”
Para 455, “admits that the Brewer firm was initially retained in March 2018 by the National Rifle Association of America and that its work included issues involving National Rifle Association of America affinity partners.”
Para 464, regarding North’s asking to see Brewer’s Billings, “admits that he believed that Dissident No. 1’s inquiries into the National Rifle Associationof America’s affairs exceeded the purview of the National Rifle Association of America President” So an employee (which LaPierre is) can tell the corporation’s president it’s none of his business how the employee spends the corporation’s money?
Para 466, “admits that he instructed Dissident No. 1 to cease and desist from attempts to interfere with certain work by the Brewer firm—including work related to Dissident No. 1’s employer, Ackerman—that gave rise to potential conflicts of interest for Dissident No. 1 (such legal matters,the “Conflict Matters”)”
Page 92, a defense: “Plaintiff’s attempt to enjoin, void or rescind alleged related-party transactions pursuant to N-PCL §§ 112(a)(10), 715(f), and EPTL § 8-1.9(c)(4) fails because, to the extent such transactions were not approved in accordance with N-PCL § 715(a)-(b), they were duly ratified in accordance with N-PCL § 715(j).” That legal gibberish means, “to the extent she seeks to recover money given me without the board of director’s authorization, as required by New York not for profit corporation law, she cannot get the money back for NRA because the board later on did ratify and approve the payments.” So he wants to keep the Attorney General from raiding his cash, to give back to the NRA, and drags in the board of directors as having retroactively approved of the misappropriations. Great. He saves his pocketbook at the price of implicating the board in misappropriations. The Attorney General will use things like that to argue for dissolving the NRA. “It’s no use to say the board will save NRA, the board is up to its neck in the corruption.”
An attorney friend just shook his head. “How can you defend this in court? And that’s just what he has been forced to admit. All those denial on information and belief, count on it, most of those New York can probably prove, too. And they’ve asked for a trial before a New York City jury? Incredible.”
As I’ve said, the NY Attorney General doesn’t have to kill the NRA. She just has to take part in its assisted suicide.