NRA’s Answer

Here’s the NRA’s answer. We’ll list the interesting parts, numbering them by their paragraph.

106. “The NRA admits that in 2012, Mr. LaPierre signed a memorandum discussing procedures for complying with Board resolutions governing purchasing. The NRA states that the memorandum contained inaccuracies arising from its failure to reflect policy changes enacted by the Board of Directors pursuant to its resolution dated December 21, 2005 and approved on January 7, 2006.” Oops.

170-71. “The NRA admits that it paid MMP approximately $71 million during the period from 2014 to 2020, and admits that it paid Concord approximately $26 million during the same period.” “The NRA admits that it paid Allegiance approximately $6 million during the period from 2014 to 2020.” These are the companies owned by David MacKenzie, who hosted the LaPierres’ Bahamas vacations on his 100-foot yacht.

207. “The NRA admits that Mr. LaPierre was reimbursed for expenses during the referenced period relating to, among other things, golf club membership fees.”

221. “The NRA admits that an armored vehicle was procured for the protection of Mr. LaPierre.”

222. “The NRA admits so much of paragraph 222 that alleges that Ackerman’s CEO proposed to acquire an investment property in North Texas and allow it to be used as a safe house for the LaPierres.” 223: “The NRA admits that in the wake of the Parkland tragedy, following advice from Angus McQueen that a “safe house” should be established, Mr. LaPierre and his wife reviewed several properties selected by Ackerman McQueen’s real estate broker.” 224: “The NRA admits that an Ackerman McQueen executive sent an invoice from WBB Investments LLC in the amount of $70,000 bearing the referenced annotation.” So the reports of a $6 million mansion for the LaPierres, funding by NRA members’ money, are admitted to be true.

230: “The NRA admits that during his tenure as Treasurer, Phillips failed to require adherence to certain internal financial policies and controls.”

235. “The NRA admits that it made payments to HomeTelos LP between 2014 and 2017 and admits further that Mr. Phillips later disclosed a personal friendship with an executive of HomeTelos or an affiliate. The NRA states that its transactions with HomeTelos were ratified by the Audit Committee of the NRA Board following Mr. Phillips’ disclosure.” 236: “The NRA admits that on or about September 2, 2014, Mr. Phillips executed a contract with HomeTelos LP on behalf of the NRA. The NRA states that neither Mr. LaPierre nor any other NRA officer signed the contract or participated in its negotiation. Treasurer Woody Phillips was steering NRA money to the company of a woman he was bedding.

251: “The NRA admits that following his retirement, Mr. Phillips to submitted invoices to the NRA in the referenced amounts, and that payments were remitted in response to some of these invoices. The NRA ceased paying Mr. Phillips during 2019.” Even after he resigned, or was caught and forced out, NRA was still paying him.

259-60; “The NRA admits that Mr. Powell’s salary was increased to $650,000 in the third quarter of 2017 and denies the remaining allegations set forth in Paragraph 259 of the Amended Complaint.” “The NRA admits that Mr. Powell’s salary was increased to $800,000 in January 2018 and that Mr. Phillips provided input concerning the salary increase.” Money just being thrown around.

273: “The NRA admits that a cybersecurity firm called LookingGlass performed services for the NRA during early 2018, and further admits that such services were discontinued by mid- 2018.”

289: “The NRA admits that Mr. Frazer returned to the NRA in January 2015 full-time as its General Counsel, and further states, that the salary approved by the NRA Board was initially $272,576 with additional compensation of $55,870 before the Board increased it to approximately $305,900 with additional compensation of $54,100.” Not bad for an attorney with 18 months experience.

328: “The NRA admits that Ackerman billed the NRA for purported out-of-pocket expenses, and further admits that the invoices for such expenses were generally transmitted to the NRA unaccompanied by explanatory details or supporting documents.” This is a vendor who is billing $42 million a year, sending invoices without receipts?

363: “The NRA admits upon information and belief that the principal of H.W.S. Consulting is an individual who formerly served as Executive Director of the NRA Foundation until his retirement in 2008. The NRA further admits that, until about December 2018, it was party to a Consulting Agreement with H.W.S. Consulting Inc. (the “HWS Consulting Agreement”).” This is about Harold Wayne Sheets, former head of the Foundation, who got a huge consulting contract after leaving.

373-375: “The NRA admits that it entered into a Consulting Services Agreement in 2016 to which Lockton Affinity and a former NRA employee were parties. The NRA further admits that Lockton Affinity formerly served as a broker for many NRA-related affinity insurance programs, including Carry Guard.” “The NRA admits upon information and belief that the Managing Director received consulting fees from Lockton Affinity after his departure from the NRA.” Nothing to worry about. It’s just your guy negotiating the contract is receiving money from them.

384: “The NRA admits that one of its board members, a former professional football player, performed paid consulting work for the NRA from time to time during the referenced period and received fees and expense reimbursements in connection with the same.”

399: “The NRA admits that, at certain relevant times, one of its board members received $4,000 per month for public speaking and consulting services.”

410: NRA (referring to Marion Hammer) “admits that Board Member No. 5 is a past NRA President, has been paid at various times for consulting services, and executed a 10-year contract for $220,000 annually.” 411: “The NRA further admits that it has made grants at relevant times to the United Sportsmen of Florida, but states that Board Member No. 5 did not participate in these grantmaking decisions.”

433: “The NRA admits that an employee formerly charged with processing certain expense reimbursements for Mr. LaPierre incurred an unexpected medical absence in recent years and that reimbursement of certain expenses was consequently delayed; the NRA states that the financial burdens of such delay has been borne by Mr. LaPierre, who continued to incur business expenses without expectation of timely reimbursement.” He hasn’t put in for reimbursement in YEARS? Maybe he doesn’t want a court seeing his requests?

447: “The NRA admits that Mr. Powell was paid the referenced salaries during or about the referenced periods, and further admits upon information and belief that Mr. Powell received additional undisclosed, unauthorized benefits.”

489: “The NRA admits that as of the date of this Answer North did not resign as an NRA member or NRA director. The NRA further admits that its Bylaws contemplate a process for involuntary termination from membership for cause. The NRA further admits that, in response to a Amended Complaint by an NRA member in good standing seeking the expulsion of North from the NRA membership pursuant to Article III Section 11 of the NRA’s Bylaws, the Ethics Committee of the NRA Board reviewed the complainant’s allegations and determined that they would warrant North’s expulsion if proved or uncontested. The NRA further admits that North through counsel was then advised that at the hearing, contemplated by its Bylaws, the complainant NRA member would be permitted to argue for North’s expulsion from the NRA and North would be permitted to defend himself. The NRA further admits that North originally requested to have a hearing but later alleged that the hearing would violate New York law and that the NRA then sought, inter alia, a declaratory judgment otherwise. . . .”

511: “The NRA admits that certain previous Audit Committee reports contained the notation “there were no instances of whistleblowing reported,” and that no such annotation appeared with respect to the July 30, 2018 meeting, wherein whistleblowing occurred.” So when the whistleblowers reported the matters, the audit committee quietly pushed it under the rug?

594-598: “The NRA admits that its then-Treasurer and CFO knew before the November 16, 2020 filing deadline that the NRA’s 2019 Form 990 would include disclosures regarding potential excess benefits and that he was the officer at the NRA primarily responsible for the preparation of complete and accurate tax and information return filings.” “The NRA admits that in connection with the preparation of the NRA’s 2019 Form 990, its then-Treasurer and CFO requested certifications from various individuals and that certain of the requested certifications were not provided.” “The NRA admits that its Executive Vice President and CEO Wayne LaPierre signed its Form 990 for 2019.” “the NRA admits that, on or about January 28, 2021, its Executive Vice President and CEO Wayne LaPierre informed its then- Treasurer and CFO that the NRA was going in a different direction and would be replacing him as Treasurer and CFO. The NRA admits that, consistently with its policies and procedures, after the then-Treasurer and CFO was notified of this, the NRA’s Information Services department disconnected his access to the NRA’s network.” Confirms reports that the new and honest Treasurer refused to sign the IRS Form 990, after no one would confirm its data, and was fired.