Declaration of Ian Shaw — In re NRA Business Expenditures Litigation

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The Declaration of Ian Shaw supporting the National Rifle Association's motion to transfer cases for consolidated pre-trial proceedings under 28 U.S.C. § 1407, filed October 20, 2020 as Document 1-20 in MDL No. 2979 before the Judicial Panel on Multidistrict Litigation. The declarant states he is an associate at Brewer, Attorneys & Counselors and counsel for the defendant in Ackerman McQueen, Inc. v. Grant Stinchfield, Civ. Case No. 3:19-cv-03016-X (N.D. Tex.). He attaches the complaint, the amended answer, a docket summary from PACER/ECF, a scheduling order entered April 17, 2020, and a list of likely witnesses. He states a protective order was entered October 16, 2020 and identifies the fact issues as the association's dealings with its former public relations agency and the expenses billed. He lists other proceedings with which discovery is expected to overlap.

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DECLARATION OF IAN SHAW IN SUPPORT OF THE NATIONAL RIFLE 
ASSOCIATION’S MOTION TO TRANSFER CASES FOR CONSOLIDATED            
PRE-TRIAL PROCEEDINGS PURSUANT TO 28 U.S.C. § 1407 
 
 
I, Ian Shaw, declare under penalty of perjury pursuant to 28 U.S.C. § 1746, that the 
following is true and correct: 
1. 
I am over twenty-one years of age, and fully competent to make this declaration. I 
am an associate with the law firm of Brewer, Attorneys & Counselors (“BAC”), 1717 Main Street, 
59th Floor, Dallas, Texas 75201. I am counsel for Grant Stinchfield in the matter captioned 
Ackerman McQueen, Inc. v. Grant Stinchfield, Civ. Case No. 3:19-cv-03016-X (N.D. Tex.) (the 
“Stinchfield Litigation”). I respectfully submit this declaration in support of the National Rifle 
Association of America (the “NRA”)’s Motion to Transfer Cases for Consolidated Pre-Trial 
Proceedings Pursuant to 28 U.S.C. § 1407 (the “Consolidation Motion”). Unless otherwise stated, 
I have personal knowledge of all matters stated herein.  
2. 
Attached as Exhibit A hereto is true and correct copy of the Plaintiff’s Original 
Complaint in the Stinchfield Litigation, which sets forth the plaintiff’s claims therein. Attached as 
Exhibit B hereto is a true and correct copy of the Defendant’s Amended Answer to Plaintiff’s 
Original Complaint, which sets forth Stinchfield’s affirmative defenses. These documents 
collectively constitute the operative pleadings in the Stinchfield Litigation. Attached as Exhibit C 
hereto is a true and correct copy of the current docket summary for the Stinchfield Litigation, 
generated via PACER/ECF.   
3. 
The Stinchfield  Litigation is currently in the discovery phase.  A scheduling order 
was entered on April 17, 2020, a true and correct copy of which is attached hereto as Exhibit D.  
A protective order was entered on October 16, 2020, and it is anticipated that the voluminous fact 
discovery sought by both sides will move forward shortly now that parties producing documents 
Case MDL No. 2979   Document 1-20   Filed 10/20/20   Page 1 of 2

have the ability to make confidentiality designations. Attached hereto as Exhibit E is a list of 
witnesses likely to possess facts or documents relevant to the Stinchfield Litigation.   
4.
Significant issues of fact in the Stinchfield Litigation include: the NRA’s dealings
with its former public relations agency, Ackerman McQueen, Inc. (“Ackerman”),1 including what 
Ackerman disclosed to the NRA and what NRA executives knew;2 the nature of the expenses that 
Ackerman billed to the NRA3 and the authorization obtained therefor.4 It is expected that discovery 
will overlap considerably with discovery in other NRA-related litigation including: People v. Nat’l 
Rifle Ass’n of Am., et al., Index No. 451625/2020 (Sup. Ct. N.Y. Cnty.) (the “NYAG State 
Action”) and Nat’l Rifle Ass’n of Am. v. James, Civ. No. 1:20-cv-00889 (N.D.N.Y.) (the “NYAG 
Federal Action” and, collectively with the NYAG State Action, the “NYAG Litigation”); 
Dell’Aquila v. LaPierre et al., Civ. Case No. 3:19-cv-00679 (M.D. Tn.) (the “Dell’Aquila 
Litigation”); and, Nat’l Rifle Ass’n of Am. v. Ackerman McQueen, Inc., et al., Civ. Case No. 3-
19-cv-02074-G (N.D. Tex.) (the “Ackerman Litigation”).   
5.
I declare under penalty of perjury under the laws of the United States of America
that the foregoing is true and correct.  
Executed this 20th day of October 2020 in Dallas, Texas. 
/s/ 
Ian Shaw 
1 See Ex. A ¶¶ 1-2; 9-22; See Ex. B ¶¶ 1-2, 9-22. 
2 See Ex. A ¶¶ 22-29.  
3 See Ex. A ¶¶ 11,14, 23, 26-30;  See Ex. B ¶¶ 23-25. 
4 See Ex. A ¶¶ 14-15, 22-24, 30; See Ex. B ¶¶ 24, 30. 
Case MDL No. 2979   Document 1-20   Filed 10/20/20   Page 2 of 2

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