Association of Priority Mail Users, Inc. Reply Comments on Postal Rulemaking

admin Administrative Law, Postal Law

On behalf of the Association of Priority Mail Users, Inc., our firm filed reply comments in Postal Regulatory Commission (PRC) Docket No. RM2007-1 in response to PRC Order No. 15. The APMU comments respond to the UPS comments filed on June 18, 2007, in which UPS suggested that the PRC require that competitive products recover an additional amount above attributable and above institutional costs Read More

Association of Priority Mail Users, Inc. Comments on Second Round of Postal Rulemaking

admin Administrative Law, Postal Law

On behalf of the Association of Priority Mail Users, Inc., our firm filed comments with the Postal Regulatory Commission in Docket No. RM2007-1 opposing either the attribution or assignment of assumed federal income taxes to specific competitive products and urging that they be treated as institutional costs of the Postal Service.  The Postal Accountability and Enhancement Act (“PAEA”), Read More

FDA Draft Guidance for Industry on Complementary and Alternative Medicine

admin Administrative Law, Health Law

Today, on behalf of TREA Senior Citizens League, we filed with the FDA for both Clarification of, and Extension of, the deadline for comments in response to the FDA’s rulemaking in Docket No. R2006D-0480, entitled “Draft Guidance for Industry on Complementary and Alternative Medicine Products and Their Regulation by Food and Drug Administration.”

Link to request

Association of Priority Mail Users, Inc. Comments on Postal Rulemaking

admin Administrative Law, Postal Law

On behalf of the Association of Priority Mail Users, Inc., our firm filed comments with the Postal Regulatory Commission addressing some of the problems associated with implementing the new Postal Accountability and Enhancement Act (“PAEA”), P.L. 109-435, which changes the manner in which rates are set for Priority Mail and other types of mail now classified by Congress as “competitive  Read More

United Seniors Association v. Social Security Administration Amicus Brief Filed to Attack Federal Statute Censoring 15 Political Words

admin Administrative Law, Postal Law, U. S. Supreme Court

We filed an amicus curiae brief with the U.S. Supreme Court on behalf of the Free Speech Defense and Education Fund, Conservative Legal Defense and Education Fund, Lincoln Institute for Research and Education, Citizens United Foundation, and Downsize DC Foundation in support of United Seniors Association’s (USA) petition for a writ of certiorari.

The amicus brief takes issue with the casual Read More

FSDEF Amicus Brief in United Seniors Association v. Social Security Administration

admin Administrative Law, Constitutional Law, U. S. Court of Appeals, Fourth Circuit

We filed an Amicus Brief for the Free Speech Defense and Education Fund in support of United Seniors Association’s petition for rehearing of the decision to fine them over $500,000 for using the words “Social Security” on carrier envelopes. The FSDEF brief submits that the panel misapplied the deferential agency review standard of Chevron and failed to apply the relevant Read More

Coalition for Postal Worksharing Final Comments to the President’s Commission on the U.S. Postal Service

admin Administrative Law, Postal Law

Our firm submitted final comments to the President’s Commission on the U.S. Postal Service, on behalf of the Coalition for Postal Worksharing, urging the Commission to endorse worksharing and private sector competition by: (i) requiring the Postal Service to charge separate rates for workshared services that are sufficient to cover the cost of providing those services; and (ii) subjecting Read More

Free Speech Coalition Comments to the President’s Commission on the U.S. Postal Service

admin Administrative Law, Postal Law

Our firm submitted comments to the President’s Commission on the U.S. Postal Service, on behalf of the Free Speech Coalition, Inc., addressing (i) the Postal Service’s belief that it is the final authority with respect to most of its administrative decisions, refusing to have those decisions reviewed by anyone, even by a federal court, and (ii) the danger of granting governmental powers Read More

Free Speech Coalition Comments to FEC on Membership

admin Administrative Law, Election Law

On behalf of the Free Speech Coalition, we filed comments with the Federal Election Commission supporting the proposed changes to revise the definition of a “member” of a membership organization, so long as the changes set forth in FSC’s comments are incorporated into the adopted regulations.  The first change is that membership organizations be permitted to waive the dues criterion Read More