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December 10th, 2013, 02:13 PM #1
Firearms Industry Consulting Group's Official Comment in relation to ATF - 41P
As we already drafted Attorney David Goldman's, of GunTrustLawyer.com, Comment, we were able to condense our Comment slightly, as the issues were preserved with his Comment. Nevertheless, with exhibits, our Comment is over 500 pages and you can find a copy of it here - http://blog.princelaw.com/2013/12/10...on-to-atf-41p/
Unfortunately, we were unable to obtain funding to hire the experts that should have been consulted and included with any proper and thorough submission. We were very fortunate to have several experts offer their time, pro bono. Nevertheless, due to ATF's arrogance, they failed to correct almost all of the Administrative Procedure Act violations and thus, invalidation of any final rule through judicial review should be somewhat easy; however, the Industry is going to need to get funding together to litigate it. If ATF was smart and insistent on implementing a final rule in this regard, they would start over and correct the APA violations.Joshua Prince, Esq. - Firearms Industry Consulting Group - www.PaFirearmsLawyer.com
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December 10th, 2013, 02:57 PM #2
Re: Firearms Industry Consulting Group's Official Comment in relation to ATF - 41P
Thank you so much for the effort.
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December 10th, 2013, 04:38 PM #3
Re: Firearms Industry Consulting Group's Official Comment in relation to ATF - 41P
Anyone who has downloaded a copy of our Comment before 2:55PM today, I apologize that it did NOT include Exhibit 25D, which has been corrected. If you download it now, it should include Exhibit 25D. The total page count should be 521 pages.
Joshua Prince, Esq. - Firearms Industry Consulting Group - www.PaFirearmsLawyer.com
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