Firearms Industry Consulting Group (“FICG”), a division of Prince Law Offices, P.C., continues to present evidence and argument to ATF in opposition to its proposed rule 41P. FICG drafted and filed a Comment on behalf of David M. Goldman (ATF-2013-0001-1899) that set forth arguments echoed in many subsequently-filed comments. FICG submitted its own Comment (ATF-2013-0001-8364 and ATF-2013-0001-8365) covering a wider range of objections. Earlier this week, FICG supplemented its Comment with sixty-five pages of additional argument and exhibits.
ATF’s failure to timely post public submissions throughout the comment period denied FICG and other interested persons the ability to reference and build upon useful material, on the one hand, and to rebut incorrect assertions and clarify the record, on the other hand. That problem was exacerbated by the slow pace that has continued to mark ATF’s posting of comments, with nearly 12% of all comments submitted still awaiting processing. In addition, developments subsequent to December 9, 2013, that shed light on ATF’s rulemaking proceeding had to be put on the record to facilitate later judicial review.
FICG’s Supplemental Comment can be found here.
Published by Tom Odom, Esq.
Tom was born and raised outside of Philadelphia. He attended Rutgers University as an undergraduate and, later, University of Pennsylvania School of Law where he was an Executive Editor on the University of Pennsylvania Law Review. He served as a clerk to Judge Morton I. Greenberg of the U.S. Court of Appeals for the Third Circuit.
Tom practiced law for ten years in Washington, D.C., handling matters before numerous federal administrative agencies and litigating several significant issues of federal constitutional law. He resigned his partnership for a full-time teaching position and spent the next ten years as a law professor at schools including Penn State/Dickinson School of Law, Rutgers School of Law -- Camden, University of Richmond School of Law, and Oklahoma City University School of Law. While a professor, Tom published three books on federal constitutional law and articles on various topics.
Tom joined the Prince Law Firm, P.C., due to his interest in protecting constitutional rights and the firm's reputation in representing individuals in firearms related matters. He assists clients in complying with regulatory requirements and in litigating when their rights have been infringed.
View all posts by Tom Odom, Esq.
Prince Law Offices Blog 
4 thoughts on “FICG Files Supplemental Comment in Opposition to ATF 41P”