VIRGINIA:

IN THE CIRCUIT COURT OF THE CITY OF ALEXANDRIA

 

NATIONAL RIFLE ASSOCIATION

V.

 

Case No. CL19001757, 
ACKERMAN MCQUEEN, INC. CL19002067, CL19002886

And
MERCURY GROUP, INC.

Defendants.

 

 

MOTION TO SEAL AMENDED AND SUPPLEMENTAL
COUNTERCLAIM FILED IN CL19001757 AND CL19002067
AND COUNTERCLAIM FILED IN CL19002886
Plaintiff/Counterclaim Defendant, the National Ri?e Association of Arnerica (the 
by counsel, hereby moves this Honorable Court to seal the Amended and Supplemental
Counterclaim ?led by Ackerman McQueen, Inc. and Mercury Group, Inc. (collectively the
?Defendants?) and, in support thereof, states as follows:

1. In the Defendants? Amended and Supplemental Counterclaim, deemed ?led on October 8,
2019, Defendants included allegations containing information from Mr. Wayne LaPierre?s
deposition. See Defs.? Amend. Countercl. 30, 130.

2. In the Defendants? Counterclaim, ?led on October 2, 2019 Defendants included allegations

containing information from Mr. Wayne LaPierre?s deposition. See Defs.? Countercl. 

30, 130.

 

 

 

3. The deposition of Mr. LaPierre was designated ?Con?dential? by counsel for the NRA,
and counsel for Defendants did not oppose that designation.

4. Publicly ?ling Con?dential Information is prohibited by the Protective Order entered in
this matter.

5. At the motions? hearing held in this case on October 8, 2019, the NRA orally moved to
seal the Amended and Supplemental Counterclaim and to publicly ?le a redacted version.
See Hearing Trans. pgs. 6-7.

6. does not agree that the information in those two paragraphs is con?dential, but does
not object to this Motion, and Judge Dawkins held that the deposition testimony in
paragraphs 30 and 130 of the Amended and Supplemental Counterclaim may be sealed and
a redacted version of the Counterclaim placed in the public ?le. See id.

WHEREFORE, the NRA requests that this Honorable Court enter an Order granting its request

to seal Defendants? original Amended and Supplemental Counterclaim and Counterclaim.

Dated: November 6, 2019 Respect?illy submitted,

NATIONAL RIFLE ASSOCIATION
OF AMERICA
By counsel

Jame? W. Hundley (VSB No. 30723) 
Robert H. Cox (VSB No. 33118)
Amy L. Bradley (VSB No. 80155)
BRIGLIA HUNDLEY, RC.

1921 Gallows Road, Suite 750
Tysons Comer, Virginia 22182
(703) 883-0880 [telephone]

(703) 883-0899 [facsimile]
jhundley@brigliahundley.com
rcox@brigliahundley.com
abradley@brigliahundley.corn

 

 

 

Michael J. Collins (pro hac vice)

Jason C. McKenney (pro hac vice)

Brewer Attorneys Counselors

1717 Main Street, Suite 5900

Dallas, Texas, 75201

(214) 653?4000 [telephone]

(214) 653-1015 [facsimile]

Counsel for the National Ri?e Association of
America

CERTIFICATE OF SERVICE

I hereby certify that on November 6, 2019, I caused the foregoing Plaintiff? 5 Motion to
Seal to be served via electronic mail and ?rst-class mail upon:

David Schertler (pro hac vice)
David H. Dickieson (VSB No. 31768)

Schertler Onorato, LLP

901 New York Avenue, NW.
Suite 500

Washington, DC. 20001
dschertler@schertlerlaw.com
ddickieson@schertlerlaw.corn

Counsel for the Defendants

 

James W. Hundley (VSB No. 30723)

Robert H. Cox (VSB No. 33118)

Amy L. Bradley (VSB No. 80155)

Michael J. Collins (pro hac vice)

Jason C. McKenney (pro hac vice)

Counsel for the National Rifle Association of
America