In the United States District Court for the Northern District of Texas Dallas Division
Case 3:19-cv-02074-G Document 31 Filed 11/15/19 Page 1 of 150 PageID 422 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION NATIONAL RIFLE ASSOCIATION OF § AMERICA, § § Plaintiff and Counter-Defendant, § § and § § WAYNE LAPIERRE, § § Third-Party Defendant, § § v. § Case No. 3:19-cv-02074-G § ACKERMAN MCQUEEN, INC., § § Defendant and Counter-Plaintiff, § § and § § MERCURY GROUP, INC., HENRY § MARTIN, WILLIAM WINKLER, § MELANIE MONTGOMERY, AND JESSE § GREENBERG, § § Defendants. DEFENDANTS’ AMENDED ANSWER AND DEFENDANT/COUNTER-PLAINTIFF ACKERMAN MCQUEEN, INC.’S AMENDED COUNTERCLAIM AND THIRD-PARTY COMPLAINT Subject to and without waiving Defendants’ pending Motion to Dismiss (Doc. 38), come now Ackerman McQueen, Inc. (“AMc”), Mercury Group, Inc. (“Mercury”), Henry Martin (“Martin”), William Winkler (“Winkler”), Melanie Montgomery (“Montgomery”), and Jesse Greenberg (“Greenberg”) (collectively, “Defendants”), and file this, their Amended Answer to Plaintiff’s First Amended Complaint (the “Complaint”) and Counter-Plaintiff AMc’s Amended Counterclaim (the “Counterclaim”) and Amended Third-Party Complaint against Wayne LaPierre DEFENDANTS’ AMENDED ANSWER, COUNTERCLAIM AND THIRD-PARTY COMPLAINT PAGE 1 Case 3:19-cv-02074-G Document 31 Filed 11/15/19 Page 2 of 150 PageID 423 (“LaPierre”) (“Third-Party Complaint”) and respectfully show the Court as follows: I. RESPONSE TO “PRELIMINARY STATEMENT” The NRA adds these additional allegations and claims in order to expose a stunning pattern of corruption, fraud, and retaliation by Defendants that continues to come to light. Since the NRA terminated its relationship with AMc last Spring, newly unearthed text messages, emails, and interviews with former AMc employees, customers, and others have made two things abundantly clear: First, AMc exploited decades of trust and confidence in order to siphon assets from the NRA, lining the agency’s pockets at the expense of its client and in violation of the law.
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