NY Attorney Dissolve the NRA

[xerts1191]

NRA Financials Through End of August


nraindanger
Nov 2
They are disastrous. Compare the Year To Date Actual column with the Year to Date as budgeted. The YTD budgeted would show the best estimates as of the beginning of 2022, meaning the anticipated trend in revenue, grim as it was (a fall from the peak years 2017-2018, of $350 million down to the estimated 2022 revenue of $268 million. A 24% drop--a financial disaster.

That was the grim prediction. The reality is worse. January-August 31, membership dues were predicted as $110 million; they really were only $79 million, 28% below budget. Contributions for ILA, predicted at $20 million, only brought in $12 million. ILA cut back its spending (in an election year) and spent $19 million, out of a budgeted $24 million. Even so, when the budget projected a $676,000 surplus at this point, NRA actually ran an $11 million deficit.

Expenses: The standout is the legal costs, listed under "OGC_Secretary" (Office of General Counsel). That was budgeted for a eye-popping $26 million, but actually cost $40 million. Twice as much was spent on legal costs as was spent by the entire of ILA! Legal bills ate up more than ILA and General Operations put together. They are now 29% of NRA's entire budget; no corporation can survive legal expenses like that. At what point will the board recognize that LaPierre and his cronies are too expensive a luxury for hard times?

 

[xerts1911]

Site logo image NRA in Danger
Further Thoughts on NRA’s 2022 Finances


nraindanger
Nov 3
Since the previous post, we've had time to reflect. The financial report shows finances through the end of August, 8 months. We can project the year by multiplying the year to date numbers by 1.33. NB: these will be optimistic projections, since the trends are clearly down, rather than stable.

Projections for the year 2022: revenues, $184 million, expenses $222 million. Deficit, $38 million. The budget had shown a deficit of zero, but this is the actuality. One-sixth of expenses will have to be met by borrowing, despite all the budget cuts and hiring freezes and stopping contributions to employees' pensions. 2023 will probably worsen the deficit, the trend continuing down, and eventually the line of credit NRA borrows against will be exhausted. By the way, projected legal expenses for 2022 are $60 million, or over 1/3 of NRA's total revenues.

Looking at past NRA 990s, in 2018 NRA had total revenue of $352 million, four years later that's fallen by 37%. In 2019, NRA ran a deficit of $12 million, in 2018, a deficit of $2.7 million, in 2017 a deficit of $17 million, and in 2016 one of $45 million. Even in the good years, NRA was spending more than it brought in. The one exception is 2020, when revenues fell only $4 million, and NRA showed a surplus due to salaries being cut by 1/3 ($18 million) via layoffs, unsalaried furloughs, salary cuts, and stopping contributions to employees' retirement funds.

If you were looking at a company, and noted that its revenues had fallen by 37% over four years, it'd laid off many employees and stopped its pension contributions for the rest, it was kept alive only by massive borrowing (1/6 of its budget), it's tied up in legal battles to where its legal budget consumed 1/3 of its revenues, and everything was pointing down for coming years, wouldn't you conclude the company was dying, and the only question was when would it file for real (dissolution) bankruptcy and fade away? Give it a six months or a year, and it will be down there with Blockbuster, Circuit City, and Toys-R-Us.

If you learned that at a meeting of the company's board, one director had moved for the board to be given the full financial data, and the others let his motion die for lack of a second, wouldn't you conclude that the reason why the company was dying was obvious? The company is dying, and its board of directors closes their eyes and plugs their ears and say "go away, we don't want to think about it."

 

[xerts1191]

Site logo image NRA in Danger
Strange Turn In The NY Lawsuit


nraindanger
Nov 6
NRA has been fighting to keep secret the "Frenkel Report," a document drafted by attorney Jacob Frenkel in 2007. It seems that every NRA board member had received an anonymous letter informing them of financial misconduct, including some by Millie Hallow. NRA objected to producing the report in front of the special master handling discovery, lost there, appealed to the judge, lost again, and is now trying again before the judge. That report must be very incriminating. (Clue: Frenkel specializes in white-collar criminal defense and in defending against regulatory actions).

NRA filed, for the judge's reference, New York's position filed with the special master. It contains some startling items:

"For example, the general ledgers should demonstrate NRA funds paid to a group of related entities and individuals, through NRA Executive Vice President Wayne LaPierre’s office’s budget, and other budgets centers within the NRA, to a group of related entities and individuals owned by or affiliated with non-party David McKenzie. Evidence indicates that the NRA has paid the McKenzie entities thus far well over $100 million, often with verbal approvals in excess of contracted amounts in violation of NRA policies. The evidence also indicates that payments to the McKenzie entities were internally allocated to various NRA cost centers and dispersed through payments to various affiliated business entities, some located within the same offices within the NRA headquarters, with the same staff, same leadership, and little to no division in their work. This internal accounting obfuscates the magnitude of the amounts paid by the NRA to these businesses. Indeed, there is evidence to suggest that the NRA paid monies to at least one of McKenzie’s businesses, Associated Television Inc. (“ATI”)1, without receiving promised services in return. Witnesses have been unable to testify as to what monies were paid to these entities and insiders and when such payments stopped, if they have. It was only during his testimony at the bankruptcy trial that Defendant LaPierre revealed for the first time his relationship with David McKenzie, including gratis use of McKenzie’s luxury yachts. During his testimony in this action, Mr. LaPierre revealed previously undisclosed information that further establishes a conflict of interest. Mr. LaPierre testified to having received additional expensive gifts and favors from the McKenzies, including paid luxury vacations to numerous exotic locales around the globe for himself and his wife and his wife’s use of McKenzie’s yachts for “girls” and family trips."

Footnote 1:"Mr. LaPierre testified at his deposition on June 27 and 28, 2022, that ATI produced the Crime Strike television series for the NRA. He claims to have filmed segments of this show while in Monaco, the Bahamas or on board the McKenzie’s yacht, thus making his receipt of such free luxury travel, at least in part, a business expense. Mr. LaPierre had not seen the episodes of Crime Strike he allegedly filmed since 2014 and does not know if they aired. Plaintiff asked for information relating to the Crime Strike show, including videos, from the NRA in Plaintiff’s first request for production, no. 38. None were produced. Plaintiff has narrowed the request to episodes including the video filmed in Monaco, the Bahamas or on board a yacht and any evidence showing that such episodes were actually aired. While producing some correspondence with ATI, the NRA has refused to produce the limited video footage sought or to confirm that it does not have information regarding whether such episodes aired. See Ex. B. Plaintiff also asks for an order directing the NRA to produce the requested episodes and evidence, if it has any, of such episodes ever airing."

"During the deposition of NRA Vice-President, long time Board member and Audit Committee Vice Chair David Coy on June 15, 2022, Mr. Coy testified that he drafted a document relating to an “anonymous letter that BOD members received prior to the April 2007 NRA Annual Meeting.” . . . . The document indicates that in 2007, a whistleblower raised some of the identical claims of corruption, waste and lack of adequate internal controls to the entire NRA Board that the Plaintiff is alleging has more recently occurred and in some instances is still occurring within the NRA."

If anyone on the board believes that these are minor matters that will blow over, it's time they took their head out of the sand. Over $100 million to one vendor alone, whose businesses gave their address as NRA HQ? He bestows expensive gifts on the CEO? Millions for a TV program that never aired? Whistleblowers 15 years back, and the board not bothering to investigate?

 

[xerts1191]

Site logo image NRA in Danger
NRA 2021 Form 990 Online


nraindanger
Nov 19
Here it is, submitted last week. We see some interesting things.

The organization is getting hammered financially. Contributions fell from $105 million to $84 million, and total revenue from $282 million to $227 million. In its peak year, 2018, just before the scandals broke, total revenues were over $350 million. 2021 figures show a decline of 35% in three years.

This did not stop the organization from paying $11 million to one "consultant" (owned by the fellow who gave the LaPierres vacations and the use of his yacht, and which gives its address as NRA HQ), $13 million to a fundraiser, and $20 million to attorney Bill Brewer.


Another thing: NRA got into a legal battle with Chris Cox, who was head of ILA until LaPierre suspended him. Thereafter, Cox agreed to a severance payment, of something over $2 million. Then NRA sued him over that. A year ago, we reported that NRA has already paid Brewer's law $8 million, to fight a $2 million case. The Form 990 discloses that NRA paid Cox $2.4 million in damages and paid his attorneys $3.7 million. So NRA was on the hook for at least $11.7 million in legal fees, to arbitrate a $2 million case!


The only sense we make of that is that LaPierre had a grudge against Cox, and if it cost NRA $11 million to act it out, well, it didn't come out of LaPierre's pocket. It came out of the members' pockets.

Miscellaneous: By the bylaws, directors are uncompensated volunteers, but Marion Hammer got her usual $270,000, not bad for 5 hours work a week (also reported on the 990). Add to that her $110,000 from United Sportsmen of Florida, which is mostly financed by ILA. NRA's total legal outlays were $36 million; the difference between this and the Brewer firm's billings were probably attributable to the NRA's failed bankruptcy filing that year. We've projected that NRA's legal expenses for 2022 will be a ruinous $60.5 million. That's TWICE what NRA spent in its all-out effort to elect Donald Trump in 2016, and nearly FOUR TIMES what it spent on his electoral run in 2020.

It looks as if NRA's "leadership" has abandoned its goals of protecting the 2nd Amendment and promoting sport shooting, in favor of one of financing the legal industry

 

[xerts1191]

Site logo image NRA in Danger
Video On NRA Finances


nraindanger
Nov 25
Mrgunsngear has a Youtube video entitled "The NRA Is Going Bankrupt Due to Wayne LaPierre." It has a lot of what we've seen, and also has 58,000 views and nearly 1,600 comments in the last week.

To make sure that NRA does indeed spend $60 million on legal bills this year, the NRA attorneys appealed the judges discovery orders (including the Frenkel report, which they must really want to keep secret). John Frazer had earlier appealed the court's refusal to dismiss three counts against him, which would have required him to repay the NRA a beaucoup of money if found guilty. Neither of these appeals stops the case moving ahead. There have been 900 documents filed in the case so far, which of course explains the tens of million in legal fees.

Elsewhere in the New York case, everyone agreed to extend the filing date of the "Notice of Issue" to December 13, 2022, and the judge ordered it done. After the notice of issue, the judge can set a trial date, and we're guessing mid-2023. New York's attorneys seem to be in no hurry, probably because they understand that the NRA will bleed itself to death financially before the case can be tried.

 

[MTURBO]

I will continue to support the N.R.A.

 

[kenpoprofessor]

I will continue to support the N.R.A.

I bet you voted for Biden, Hobbs, and Kelly as well.


Clyde

 

[xerts1911]

Wayne thanks you

 

[xerts1911]

Motion To Seal in NY Case


nraindanger
Nov 28
NRA has moved to seal (file but keep secret from the public) the 2003 Frenkel report, which we've mentioned before. That report must be really hot, given that NRA leadership is fighting hard to keep it secret 19 years after it was written. All that is known is that its author, Jacob Frenkel, was a specialist in defending white-collar criminal cases. A quote from the motion to seal hints at how hot the report is, in terms of how much is being done to keep it secret.

"The sealing order is necessary because (i) the Document is privileged and otherwise non-discoverable; (ii) the NRA is pursuing two appeals (one with the Court and one with the Appellate Division) regarding any rulings to the contrary; and (iii) the NYAG agreed that the NRA would produce the document to the NYAG in the interim subject to numerous restrictions, including the NYAG's promise that should the NRA prevail on appeal, the NRA will return the document to the NRA and not use it or work product derived from it."

Back in 2003, the report was sent to the Audit Committee. That it's being kept top secret today probably means that it was kept secret from the rest of the board of directors. It must be linked to a person or persons still with NRA now or recently, or no one would care this much. Here is part of the deposition of director David Coy, which mentions that the report concerned "expenditures" and (maybe, it's not clear) "II and IS," which were the companies owned by the mysterious unlicensed travel agent who leased executive jets for LaPierre

 

[Jay Gee]

I just can't believe the board of directors voted him in again. GOA and 2A foundation is where my money goes now.

 

[xerts1191]

Yeah it makes no sense whatsoever, the ship is sinking, and yet the band plays on

 

[xerts1191]

Site logo image NRA in Danger
How You Run Up Millions In Legal Bills


nraindanger
Dec 12
In the New York case, NRA moved to dismiss on the ground it was described in the complaint as "National Rifle Association of America, inc.," when its legal name didn't have "inc." in it. The judge said this was not very important, and directed the two parties to confer and submit an order for his signature that would correct the technical error.

NRA didn't, but continued to object. The judge finally issued an order, saying in it:

"Later on December 1, 2022, counsel for Defendant Wayne LaPierre submitted a letter (NYSCEF 911) requesting until December 9, 2022, to file a response. On December 9, 2022, despite the Court’s clear and unequivocal order to submit a proposed order to make a simple change, the National Rifle Association (NYSCEF 913), Mr. LaPierre (NYSCEF 916) and Mr. Frazer (NYSCEF 920) submitted letters requesting that the Court require OAG, in addition to amending the caption, to “(i) amend the summons and complaint; (ii) serve the amended summons and complaint on the NRA; and (iii) file the amended summon and complaint along with proof of their service” (NYSCEF 913). Notably, no argument has been made that any party has been prejudiced or confused by the apparently incorrect addition of “Inc.” to the NRA’s name in the pleadings under which the parties have been operating for more than two years."

"OAG’s straightforward request to change “National Rifle Association of America, Inc.” to “National Rifle Association of America” in the caption and complaint is GRANTED. . . ."

Motions and counter-motions over three letters and a period. That's how you churn up millions in legal fees, and irritate the judge

 

[xerts1191]

NY Case: Attorney-Client Privilege


nraindanger
Dec 17
Attorney-client privilege protects the ability of attorneys and clients to communicate, and generally results in those conversations being "off limits" to courts and to their opponents.

It sounds as if NRA's leadership is getting attorneys involved at every level of its decisions, and then arguing that the decisions cannot be probed. It's insisting that it has reformed and made a 360 degree turn (why it chose that simile is beyond us, since that turn just puts you back on the same course), but if NY wants to probe that, "you can't see that because all our reforms were based on the advice of our attorneys."

The NY Attorney General is challenging that in a motion.

"In a November 29, 2022 decision (“Decision” or “Dec.”), the Special Master held that the NRA “seeks to cloak essentially all of its ‘course correction’ and ‘360° review’ initiatives as privileged merely because the NRA included attorneys in those efforts. . . ."

"As Plaintiff will demonstrate in its anticipated motion papers, the NRA put at issue and then blocked testimonial and document discovery of issues it asserts as evidence of its reform efforts, including: (1) the determination and calculation of excess benefits by Wayne LaPierre and other NRA executives (specifically that that the determinations and calculations were complete and accurate); (2) the NRA’s investigations, including into: (a) Defendant Wilson Phillips’ conduct as CFO and Treasurer and his receipt of private inurement, (b) whistleblower retaliation specifically relating to the Brewer firm, (c) board member travel, (d) use of an NRA vendor (Ackerman McQueen) to pay for personal expenses incurred by NRA employees, (e) diversions of assets, (f) Board member Marion Hammer payments, and (f) conflicts of interest, including the LaPierre family’s relationship with the owners of several of the NRA’s largest vendors; (3) the NRA’s handling of whistleblower complaints, including the investigation of the same and treatment of complaints (which it largely delegated to litigation counsel) as well as those complaints not deemed to be made by whistleblowers. . . (4) reform of vendor relationships and compliance with contract procurement policies including those relating to Membership marketing Partners and related entities, Ackerman McQueen, Affiliated Television International, and Gayle Stanford-related entities; (5) Audit Committee review of allegations of wrongdoing and conflict of interest by defendant Wayne LaPierre, the signing of the NRA’s 2019 IRS Form 990 filing, and allegations in the Complaint; and (6) work done by K&L Gates, Morgan Lewis, Don Lan, the Brewer firm and other outside counsel and consultants hired as part of the NRA “course correction” and touted by the NRA as evidence of its good faith reform efforts."

"Specifically, Plaintiff will identify areas where the NRA used privilege as a sword and a shield, placing matters at issue but blocking Plaintiff’s ability to obtain discovery of the same and ask either that the NRA be precluded from introducing evidence relating to such topics or that privilege be deemed waived as to those topics, with discovery pertaining to these issues being permitted and other appropriate remedial relief. Plaintiff also asks for a conference to discuss next steps in this action, including the timing and process for summary judgment and expert evidence motions

 

[xerts1191]

“Excess benefits by WLP and other NRA executives”
“Conflicts of interest with WLPs family and certain vendors”

 

[xerts1191]

Site logo image NRA in Danger
Another Defeat In The NY Lawsuit


nraindanger
Dec 27
There was a fight over the "Note Of Issue," the document certifying that all discovery is done, and must be filed in order to get a trial date set. NRA's attorneys are still fighting NY's attempts (successful to date) to get certain documents, especially the "Frenken Report." As we've noted before, that 2003 report must be hot, if they are fighting to keep it secret nearly 20 years later. The fact that its author was an attorney hired by NRA, who specialized in white-collar criminal defense, may give us a clue. . . . He must have said, "you are SOOO screwed."

NRA's attorneys have been trying to delay as much as possible (they know they'll get killed at trial), while telling the board that NY is dragging its feet. In this exchange they argued the Note Of Issue shouldn't be filed until those discovery disputes were settled. The judge disagreed, and ordered the Note filed, with NY allowed to reserve the right to finish the discovery fight while the trial date approaches. NY filed it early.

NRA's attorneys had requested a jury trial (which was an insane move--why did they want to try this to a Manhattan jury?), and the Note Of Issue reflects this. A jury trial it is.

Yet another loss in the case, and a bad move stuck down the attorneys' throats. NY gave them what they asked for, good and hard.

 

[smithers599]

Yet another loss in the case, and a bad move stuck down the attorneys' throats. NY gave them what they asked for, good and hard.

But NRA's law firm got paid, from the remainder of the NRA's assets. They will keep litigating lost causes until all the money has been sucked out; only then will they stop. They're crying all the way to the bank.

 

[xerts1911]

Site logo image NRA in Danger
More On The Frenkel Report


nraindanger
Jan 4
NRA's attorneys are still fighting to keep the Frenkel Report, from 2007, secret. Having lost before the Special Master, lost a second time before the Special Master, and lost before the judge, they have now filed an appeal. The only question is whether they've spent tens, or hundreds, of thousands of members' dollars trying to keep it secret.

So what can be in that report that is so terrifying 15 years after it was written? We know a few things that may give clues. We know that NRA commissioned it, and that the author was an attorney specializing in defending white-collar criminal cases. It likely concerns someone highly-connected at headquarters, and who either is still there or was there recently; otherwise why worry about keeping a report secret. Two former NRA directors recall that, around 2007, every director received an anonymous letter detailing how Millie Hallow, LaPierre's closest assistant (and a convicted embezzler) was using NRA money to buy expensive clothing and shoes for herself.

An educated guess would be that, whatever she was doing, it was big enough and caused serious enough concerns that HQ hired a white-collar criminal defense expert to tell them what to do about it.

Another educated guess would be, whatever he told them to do, they didn't. Otherwise, they'd wouldn't be fighting so hard to keep the report secret.

It's also possible that his inquiry turned up other serious problems that the leadership doesn't want to see the light of day, especially since it'd show the corruption dates back at least 15 years (some of our sources say the corruption dates back into the 1990s, making it more like 25 years)

 

[xerts1191]

NRA Demands Jury Trial


nraindanger
Jan 9
We jumped the gun when we early said that NRA had demanded jury trial. But now it's done just that. NRA's demand says that the NY Attorney General had demanded jury trial only as to some issues, but NRA demands it as to all issues in the case.

"Therefore, the National Rifle Association of America (the “NRA”) hereby demands a trial by jury of all issues triable of right by a jury, including, but not limited to, issues of fact related to each element of (i) Plaintiff’s claims; and (ii) the NRA’s defenses." John Frazer and Wayne LaPierre demand the same.

This is insanity, we can find no other word for it, and our attorney friends agree. The judge seems actually to be impartial and concerned with doing the right thing. Why would NRA and LaPierre demand to be tried instead by a Manhattan jury? If we searched, could we find a worse group to try NRA?

Maybe the attorneys think this will increase their fees, or maybe we should be seeking answers from this movie..

 

[xerts1191]

Site logo image NRA in Danger
Reports From January NRA Board Meeting


nraindanger
Jan 11
We've been collecting reports from observers, and here is a summary:

There were about 20 spectators, and about 1/3 of those were staff, or directors' spouses. The spectator section was about one-quarter full, when in past years it was packed. 25 directors, a third of the board, was absent.

President Charles Cotton's address was mostly aimed at rival pro-gun groups, which after Bruen have filed and won challenges all over the country, while NRA has been MIA there. He said around 200 suits have been filed by the other groups, but that Bruen was NRA's case, as it sure was, and that the other groups are just building on Bruen's foundation.

VP Willis Lee gave a lively presentation, and said that they'd keep up with efforts to relocate HQ to another state. VP David Coy spent his time denouncing the NY Attorney General's "scurrilous vendetta."

Wayne LaPierre gave the usual presentation, and the board gave polite applause at the end. In presentations at previous meetings, they'd given him a standing ovation before he started, but not this time. He said that NRA would appeal to the Supreme Court the dismissal of its First Amendment lawsuit against NY (which means lots for $$$ for the Brewer firm, which lost at the trial level and on appeal).

LaPierre said NRA membership is at 4.3 million (that figure is high by our estimates), which he admitted was "not the highest ever." No, even that number would mean a decline in total membership of 1.2 million, at a time when it should be increasing with Biden & Co. helping to boost it. (This also means annual-dues paying membership must have fallen disastrously. That class of membership is something under half of the total, the other part being life members who will pay no dues in 2023. If peak total membership was 5.5 million, annual dues payers would have been 2.7 million or so. All of the decline in memberships would have been in this class, meaning it fell from 2.7 to 1.5 million, almost cut in half. There went NRA's dues revenues).

LaPierre also said that he'd be proposing a "conservative budget" for NRA, and blamed inflation (how would that hurt contributions?) and the economy -- rather than himself. The budget is already cut to the bone -- 2022 was $207 million, down from $350 million four years before -- and "conservative" can only mean cut still further.

He expressed hope that the NY litigation will be done by the "end of summer" (he didn't say how it would end; obviously without him as EVP) and then NRA can get back to funding its regular programs (rather than its attorneys). That is, of course, unless NRA is ruined financially before then

 

[xerts1191]

Deposition Of NRA Treasurer Sonya Rowling


nraindanger
Jan 14
Sonya Rowling became NRA CFO and Treasurer after LaPierre fired her predecessor, Craig Spray. (Just to be clear, Rowling and Spray both seem to be honest; it was Spray's predecessor, treasurer Woody Phillips, who was involved in so many suspicious deals and took the Fifth about them). Here is her deposition. The high points:

P. 21 LaPierre has not turned in expense reports for 2019 (deposition was taken in March 2021). This suggests to us that he doesn't want anyone seeing them until the court cases are done and they can't be subpoenaed.

P. 25-26. NRA HQ issued American Express cards to certain individuals. Charges to them got minimal review -- Rick Tedrick, then the treasurer.

P. 63. What effort did NRA make to ensure that Ackerman McQueen wasn't "passing through" improper travel billings? Answer: the treasurer (Woody Phillips) was neglecting his duties there.

P. 66. Why did LaPierre personally sign the 2019 IRS Form 990? Objection, attorney-client privilege. (Always before, it'd been signed by the treasurer, but Craig Spray refused to sign it after no one would show him supporting materials or vouch for it. This was probably what got him fired).

P. 71. On the 990, it says that a copy has been provided to all members of the corporation's governing body (the board) before it was filed. But it wasn't. Why? Objection, attorney-client, it was done on advice of counsel.

P. 88. Thinks Millie Hallow repaid NRA for money misappropriated, but doesn't know. (Remember, this is the treasurer and CFO).

P. 113. Whistleblowers' concerns were prompted by Carry Guard (the disastrous insurance program). And "There were -- we were asked as an accounting department to do some things outside of our practices that we were not comfortable with at all."

P. 130 ff. A description of the meeting where the whistleblowers made their report to the Audit Committee. The whistleblowers requested that board attorney Steve Hart leave the room--sounds like they were concerned he was so enthusiastic in favor of their report that he might go overboard. Says a lot for him, and suggests why LaPierre promptly fired him. Meeting lasted somewhat over an hour. Audit Committee chair Charles Cotton and member Carolyn Meadows left in the first five minutes (!!!! This wasn't important enough to listen? More likely, they didn't want to get involved).

P. 135. Rowling's notes show she was concerned the meeting was being manipulated so as to focus on the problems discussed as if they were narrow issues to be papered-over, when the issues were serious and broad.

P. 142. NRA is paying Marion Hammer's attorneys in her (private, and failed) lawsuit alleging email harassment. (So NRA is paying her attorneys, when if she had won, she and not NRA would have gotten the money).

P. 146. List of some (former) holders of NRA Amex cards at the time of the bankruptcy. "Craig (Spray), Rick (Tedrick), Carolyn Meadows and Charles Cotton, Joe -- Joe DeBergalis."

P. 149-150. Whistleblowers' concerns included $1.8 million paid for rental of a house owned by David Stanton, a/k/a David McKenzie, an owner of Associated TV. (and of several NRA vendors, and who gave LaPierre stays on his yacht in the Bahamas). She is not aware of any NRA investigation of Associated TV. Concerns also that one of Stanton/McKenzie's companies, MMP, was billing NRA in excess of its contract amounts.

P. 170-172. MMP, one of Stanton/McKenzie's companies, had a contract calling for it to be paid $400,000 a month, yet it was billing and being paid $961,850 a month. Her understanding was that treasurer Woody Phillips had verbally approved the larger billings. (We're talking a half-million a month). She cannot recall who told her that. (Yes, everything is out of control, to where a half million a month just slips through the cracks).

P. 173. Since Craig Spray became treasurer, is she aware of any agreement with MMP to increase their pay? She is not aware of it. (This is the CFO speaking, who before then was the head of accounting operations).

P. 260. Counsel observes that the Brewer law firm received $17.5 million in the last 90 days, and over $50 million