As many of our viewers are aware, Firearms Industry Consulting Group, a division of Prince Law Offices, P.C., has spearheaded the opposition to ATF’s most recent rulemaking proposal, ATF-41P. Yesterday, we filed our formal Comment in opposition to ATF 41P. With exhibits, it is over 500 pages. You can download a copy here.
As we previously drafted Attorney David Goldman’s Comment, of GunTrustLawyer.com, we were able to somewhat condense our Comment by citing to his already filed Comment, which preserved the issues. You can find the Comment we drafted for Attorney Goldman here.
While our Comment may seem massive to some, with funding, a thorough Comment with evidentiary support, including expert affidavits, reports, and analysis, would have likely been almost double in size. Nevertheless, ATF’s failure to comply with the Administrative Procedure Act in a number of ways will allow for judicial review, if ATF decides to move forward with promulgating any final rule. If ATF is inclined to move forward with any final rule, it’s best course of action is to start anew and correct all of its violations of law. But, we know ATF won’t do that, because it cannot admit when it violates the law.
Hence, the Firearms Industry must prepare to fund the necessary litigation to invalidate any final rule.
UPDATE: If you downloaded a copy of the Comment before 2:55PM on December 10, 2013, it did not include a copy of Exhibit 25D. The file has been corrected to include a copy of Exhibit 25D if now downloaded.