Firearms Industry Consulting Group (“FICG”), a division of Civil Rights Defense Firm, P.C., is honored to announce that Chief Counsel Joshua Prince and Attorney Adam Kraut drafted and filed a 923 page Comment in Opposition to ATF’s proposed rulemaking on bump-stock-devices (docket no. ATF 2017R-22 ) on behalf of Firearms Policy Coalition (“FPC”) and Firearms Policy Foundation (“FPF”). A copy of FPC/FPF’s Press Release can be found here and copies of the massive Comment in Opposition and 35 Exhibits can be found here.
Humorously, it appears that FICG broke the eRulemaking Portal, as ATF was unable to upload all exhibits (i.e. videos) and had to break the exhibits up over two separate comment IDs:

It bears substantial mentioning that Patton Media and Consulting and former Acting Director of the Firearms Technology Branch and Senior Analyst Richard (“Rick”) Vasquez of Rick Vasquez Firearms LLC were instrumental in providing irrefutable evidence that ATF has purposely misled the public on the function of bump-stock-devices. While this would undermine the efforts of an administrative agency with a sterling reputation for candor, as reflected in the Comment, ATF has a well-documented record of “spinning” facts and engaging in outright deception of the courts, Congress, and the public. Thus, it is imperative that the current Administration appoint a director to ATF, who has a stellar reputation for candor, honesty and upholding the law as written, so that ATF’s extremely tarnished reputation might be rehabilitated.
If you or your company wish to file a comment in support or opposition to a notice of proposed rulemaking by a federal administrative agency, contact Firearms Industry Consulting Group today to discuss your rights and legal options.
Firearms Industry Consulting Group® (FICG®) is a registered trademark and division of Civil Rights Defense Firm, P.C., with rights and permissions granted to Prince Law Offices, P.C. to use in this article.
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Published by Joshua Prince, Esq.
With our 2nd Amendment rights being attacked at both the Federal and State level, and the ATF (Burea of Alcohol, Tobacco, Firearms, and Explosives) trying to close down FFLs (Federal Firearms Licensees) for minor infractions while making FFLs the scapegoat when the ATF's records are inaccurate, I want to take this opportunity to introduce myself. I am one of only a handful of attorneys across the US that practices in the niche area of law known as firearms law. I decided to concentrate my legal practice on firearms law not only because I am a shooter and firearms enthusiast, but also to ensure that our inalienable Right to Keep and Bear Arms is never encroached upon.
I handle cases at the Federal and State level for both FFLs and individuals. At the federal and state levels for individuals, I actively defend the 2nd Amendment of the US Constitution and Section 21 of the PA Constitution, as well as, help individuals with:
- License to Carry Firearms Denials;
- Challenges to Erroneous PICS Denials;
- Relief from Firearms Disabilities;
- Estate Planning Advice;
- Gun/NFA Trusts; and
- 42 USC 1983 Actions for Deprivation of Civil Rights
At both the state and federal levels, I represent FFLs and SOTs throughout Pennsylvania and the US regarding:
- ATF Compliance Inspections;
- Warning Letters and Hearings;
- FFL Revocations;
- Corporate Structure Advice
- Indoor/Outdoor Range Implementation; and
- Forfeiture Proceedings
In following my love for firearms and firearms law, I have taught several Continuing Legal Education (CLE) seminars on Firearms in Estates and Trusts and Firearms Law 101 for several Bar Associations, including Berks, Cumberland, and Dauphin Counties. I also planned and taught several Firearms in Estates CLE classes for the Pennsylvania Bar Institute (PBI).
While at Widener Law School, I was a member of the Widener Law Journal. I wrote an article on the Inaccuracy of the National Firearms Registration and Transfer Record (NFRTR). I also had an article published on Fee Disputes in Workers Compensation cases in the Widener Law Journal, Volume 18, No. 2.
You can often find me posting on several internet forums, including Subguns, Uzitalk, AR15, and PAFOA. I also hold PA Firearms Law classes for local ranges to inform the public on the firearm laws of the Commonwealth.
Following in my father's footsteps, I am also a Board member for the Pottstown Police Athletic League (PAL).
View all posts by Joshua Prince, Esq.
It was all my fault about the website crashing. I left such a blistering 5 paragraph comment, the heat caused the Hard Drives to overload!
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If it was the government web site that “crashed”, perhaps this problem was a “solution” to the problem of significant, adverse public comment.
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Or so much feces hitting the fan blades the motor seized!!
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As to the ATF ” is misleadingthe public”, putting it in reasonably polite terms, THE ATF LIES LIKE THAT PROVERBIAL BIGELOW CARPET.
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as soon as possible i will be purchasing one of these devices. because both the feds and PA legislator don’t want me to.
Thanks for keeping up the good fight!!
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Re the referenced desires of both the Feds and PA Legislators, in polite terms, devil take the above referenced.
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