2257 Comments Filed at DOJ - And a demand for a formal hearing at OMB
 

They say it's better to light a single candle than to curse the darkness. I'm hoping that I've just lit a road flare and tossed it at DOJ. Using a very obscure provision in federal law, I've petitioned the Office of Management and Budget to conduct a formal hearing into the economic burden of these regulations on not only the adult industry, but on ordinary Americans. I did this in face of the statutory obligation imposed on DOJ to assess these costs, and the failure or refusal of DOJ to "certify" the truth of its pretty-crazy under estimates. When they said that they just could not determine the economic impact, I'm asking why they didn't knock on the door of the FBI down the hall, the most powerful investigative tool that's ever existed on Planet Earth, and under the command of the same Attorney General who promulgated these regulations and who is now asking for them to be rubber-stamped.

I'm hoping to turn what should be a very routine re-approval of these regulations, as is required from time to time, to turn into something very non-routine. Cross your fingers. Regardless of the outcome, I've lit at least a candle here, and time will tell whether what I've done will have any traction.

The Comments and Petition for Hearing can be read here - http://www.xxxlaw.com/section-2257/2257%20Comments.pdf

My brief announcement summarizing it is found at http://www.xxxlaw.com/news/index.html.

These comments were due before midnight, DC time, so I had them in the hopper about an hour early.

That's awesome!

I'm on my mobile so clicking around is hard, but is your demand in line with all of the government forms that say 'this should take 20' minutes to complete?

Funny thing is the time on those forms are always way longer than the average person needs, but 6 minutes or whatever it is should he enough time to comply with a complex record keeping law.

That's fucking hilarious!

It was like three days running till after midnight to get it done.

JD

I downloaded the comments PDF to my phone and read it. Great job! 38 meaty pages full of valid arguments. Thank you for taking the time to commit all of that to paper and submitting it. Hopefully we'll see some changes down the road.

That's awesome, Joe. Your work is great fir the industry and I hope people in the industry are taking note.

I know today was crunch time for you. After you sleep, spell check your summary on your web page.

Hey Joe, just wanted to drop a line and offer words of appreciation for what you are doing for our industry. Thanks.

Cheers :)

But Joe But Joe But Joe, I'm confused.
Correct me if I'm wrong, but I thought you were PRO-2257?!? As in, you think it's a good idea!
Not accusing you of any wrongdoing there, in fact, it's a great way to prove we're not doing child porn... so am I mistaken?

I'm truly not pro-2257 and I've always expressed everywhere the hope that it gets declared unconstitutional. Until lately, I've not been optimistic that this is realistically likely. There is some chance of it now. Less than 50/50 in the end, but possible.

I've always urged compliance with it to avoid convictions and prison. I don't think this is law to take a civil disobedience stand on. And yes, I've pointed out that compliance assembles the defense tools for a mistake of fact defense in an underage model situation. I can understand where some people might misunderstand me to be its supporter when I've pointed out that advantage - and some others it provides.

Were I in Congress, I never would have voted for it.

Very much appreciated. It was three sold days of hell to get it done, right on the heels of a very big project in my office, and that on the heels of taxes. I have forgotten what it feels like to take a day off.

Yeah, I saw that. Not only spelling, but some sentences without verbs and a couple of missing words. But I saw it as I looked it all over after it went out. And unfortunately, there really isn't a process to revise or correct those artifacts of time crunch. There would be process to revise and correct them in an appeal in court, but not here. They do no harm. And it's not my way to sanitize or correct them for public consumption. Like the Romans, I don't mind being seen "warts and all" as the Romans told their sculptors. It's a good solid job, and like all things and persons human, it is imperfect.

Let's all just hope that it works. I don't think anyone has ever tried this before, and so we're on a road uncharted. And it may just precipitate some good things for many people. That's what I hope.

No, thank YOU for those kind words.

Next time you hear a lawyer joke or hear the griping about our fees, recognize that more than you know, many of the lawyers serving this industry do substantial work without a fee for principles they believe in deeply, principles aimed at protecting you and the freedom of choice and privacy of the American people.

Take a well deserved day off Joe, then Run for Congress:thumbsup:thumbsup

AVN publishes the considerably more restrained Comments of the Free Speech Coalition.

http://business.avn.com/downloadfile...tmap_id=474297

Somehow, I like the spirit of mine better, typos and all.

JD

Keep up the fight!

I'm not taking about the filings, but rather the few paragraphs on your web page here:
http://www.xxxlaw.com/news/

Thre's certainly a process to correct that - Posts > Edit

People reading the filings may be accustomed to reading statutes with sentences of 357 words, so whatver is in the filing, screw it. I'm talking about the few paragraphs on your web page where you announce it.

OK, thanks for that. Five typos corrected. XXXLAW is officially indebted to you for proofreading services above and beyond the call of duty and now reflected at http://www.xxxlaw.com/news/index.html. BTW, it's not on wordpress so I either do it by code or use a what-you-see-is-what-you-get editor like Komposer. Given up on my old standby version of Dreamweaver that can't cope with php, it's so old.

Joe,

Thank you for taking the time to do this for all of us.

We sincerely appreciate your good work and dedication.

Just be thankful you're not a doctor. :thumbsup Ask any how they're doing and they'll start talking about reimbursements being down and expenses always going up.