hoffmang, I've got a wager for you.
If OAL accepts your petition for review and agrees that the "only legally tenable interpretation" of the assault weapon law is that a semiauto, centerfire rifle (AR or AK) equipped with a Bullet Button does not have the capacity to accept a detachable magazine, I will give you an M1 Garand that I got from the CMP a few years back. It's one of the non-import, USGI service grade rifles. It's been sitting in my safe, I haven't shot it.
If OAL accepts your petition and says there is a legally tenable interpretation that a semiauto, centerfire rifle (AR or AK) equipped with with a Bullet Button does
have the capacity to accept a detachable magazine, you buy me a new surfboard. New custom boards run around 700 bucks.
I will write a letter encouraging OAL to accept the petition for review, and if they do, to not issue a summary disposition letter on the ground that the DOJ advice letter is specifically exempt from APA requirements. The letter will argue the competing interpretation (Bullet Button rifle has
the capacity to accept a detachable magazine) and I can submit additional and/or repetitive commentary per the code if OAL decides to review the petition. I will transmit a copy of the letter to you at the same time I send it to OAL.
We are only talking about Bullet Buttons here, I think Prince 50 mag locks are legal. If OAL thinks the only legally tenable interpretation is that Prince 50 rifles are legal, you don't win the bet; if OAL thinks there's a tenable argument that Prince 50 rifles are illegal, I don't win the bet.
How does this sound?