Monday, November 3, 2014

3-D Printed Firearm Leads to Jail Time

According to Mashable, the first person to go to jail for making a 3-D printed firearm was a 28 year old man from Japan, Yoshitomo Imura.  Read more about the story here.

In Japan gun ownership is heavily restricted and there is no exception for 3-D printed guns, though the arrested man claimed he didn't understand he was breaking the law.

In Massachusetts, a 3-D printed firearm will be treated like any other firearm manufactured in your home.  Just because the technology has made it easier for more people to manufacture firearms doesn't change the legality of doing so.  For more on that subject, and to avoid ending up like Mr. Imura, check out our recent post: Is Making a Firearm in Your Home Legal?


Friday, October 31, 2014

Matthew Trask Accepts Position with Remington Arms Company, LLC

We are very excited to announce that on November 10, 2014, attorney Matthew Trask will assume the role of Compliance Manager for Remington Arms Company, LLC in Ilion, New York.  He will be managing the compliance team for their New York facility, and will be responsible for maintaining Remington’s compliance with the Bureau of Alcohol, Tobacco, Firearms & Explosives (BATFE) regulations, including the NFA, GCA, ITAR and other applicable state and federal laws.

Although this departure from Massachusetts will prevent Attorney Trask from directly representing firearms clients in the Commonwealth, Kelsey & Trask, P.C. remains committed to protecting your rights secured by the Second Amendment.  In addition to collaborative divorce, mediation and bankruptcy, Kelsey & Trask, P.C. has represented the needs and interests of firearms owners, dealers and manufacturers by assisting them in navigating the numerous local, state and federal firearms regulations.

Firearms cases in our firm were primarily managed by Kelsey & Trask, P.C. partner, Matthew P. Trask, Esq., a lifelong firearms enthusiast and 2A advocate.  However, as with any legal endeavor, Attorney Trask was always backed by a team of attorneys, support staff, public interest groups such as Comm2A and GOAL, and fellow colleagues and attorneys sharing similar interests, abilities and devotion to the firearms community.

To continue to serve the firearms community, there are some changes that our clients and prospective clients can expect to see in the coming weeks.  However we will continue to assist clients and potential clients either within the firm or through special relationships we have formed with other respected firearms attorneys in the community.

Although not actively engaging in the practice of law in Massachusetts after November 10, 2014, Attorney Trask will remain a resource to Kelsey & Trask, P.C. for developments in the laws pertaining to firearms, self defense, personal protection and BATFE compliance.   He will continue to be available for consulting by both our referral and in-house attorneys on firearms related issues.

We hope you continue to consider us a resource through this transition and into the future.

It has always been the goal of Kelsey & Trask, P.C. to provide high quality legal representation to resolve our client’s matters.  These changes reflect Kelsey & Trask, PC’s continued commitment to that goal.  If you have any questions, please do not hesitate to contact Kelsey & Trask, P.C. partner Justin L. Kelsey, Esq. at 508.655.5980 with any questions.  


Thursday, October 9, 2014

Is Making a Firearm in Your Home Legal?

This past week, a compact, inexpensive, PC controlled CNC mill produced by Defense Distributed, capable of making a metal lower for an AR-15 at home, has reignited discussions over the legalities of manufacturing your own firearm.

The Legal Framework for Manufacturers:  The Gun Control Act of 1968 places numerous requirements on firearms manufacturers holding a Type 07 (or similar) Federal Firearms License, including requirements for record-keeping, import/export registration, serialization and marking of firearms.  These legally-required markings, including a unique serial number, manufacturer’s name and location, model and caliber are often used by state and federal agencies to track, trace or register specific firearms to specific individuals.

For the most part, the GCA marking requirements meant that nearly every gun produced domestically (and legally imported) bore these markings, and could be relied on by manufacturers, consumers and authorities for their own purposes.  This monopoly on marking largely resulted from the fact that the manufacture of a firearm was something best left to the professionals; a skill more appropriately left to the manufacturers, and not the casual tinkerer.  In recent years, the firearms industry has seen huge advances in technology that no longer require a machine shop or knowledge of a Bridgeport milling machine.  Inexpensive CNC mills, 3D printers and 80% components and their completion kits have made the challenge of building a personal firearm available to the casual builder.  

The Legal Framework for Individuals:  Making a firearm for personal use is legal.  Making a firearm for personal use without a federal manufacturing license is legal.  This has always been the case, even after the enactment of the Gun Control Act of 1968 ("GCA"). However, this right has been attacked as of late by gun control advocates – and has been advanced with renewed interest by 2nd Amendment supporters.

Before you begin, however, understand the applicable laws.  

Is it legal to manufacture a firearm for personal use? 

Yes.  Per provisions of the Gun Control Act (GCA) of 1968, 18 U.S.C. Chapter 44, an individual may make a “firearm” as defined in the GCA for his own personal use, but not for sale or distribution.

May I sell, trade, give away, or bequeath a firearm I make if I do not wish to keep it anymore?  

No.  The GCA prohibits the sale or distribution of a firearm made by an individual.  The firearm must be destroyed by approved ATF destruction techniques, and proof of destruction should be retained. 

Must my firearm have the required GCA 1968 Markings?  

No.  Marking requirements for manufactured firearms apply only to federally licensed manufacturers.  However, it is both a state and federal crime to deface, remove or modify a firearm serial number if it is already present. 

If I Make a Firearm do I have to Register It?

Federally, no, as long as it is regulated as a Title I firearm (most rifles, shotguns and handguns).  However, some states, Massachusetts included, require the registration or reporting of the acquisition of a firearm.  In the case of Massachusetts, although no federal registration is required, once the firearm were complete and functional, the builder must submit a completed FA-10 or E-FA-10 document within 7 days. 

Are there any other laws or regulations I should be aware of if I manufacture my gun? 

Yes.  The ability to manufacture a firearm for personal use does not permit the manufacture without registration of all types of firearms.  Firearms falling under Title II of the National Firearms Act (such as machine guns and machine gun components, short barrel rifles, short barrel shotguns, destructive devices and AOW’s) require compliance with the laws regulating their registration, manufacture and possession, including the National Firearms Act (requiring the payment of a manufacturing tax and registration of NFA firearms) and the Firearm Owners Protection Act of 1986 (banning the individual manufacture of machine guns).  For more on this subject see our previous post.

Some states, including Massachusetts, have additional prohibitions on disguised firearms; bans on certain cosmetic features (as found in some state’s Assault Weapons Bans); individual licensing requirements; magazine capacity restrictions and storage requirements.  In cases where a firearm is made by an individual, these laws still apply.  Be sure you are aware of your state’s laws, and if not, consult with a competent firearms attorney. 

What are the legal requirements for becoming a Federally-Licensed Firearms Manufacturer?

If the technological advances make you think you want to jump into the firearms manufacturing world with both feet to make firearms for sale or distribution, you would need to obtain a Federal Firearms License, such as a Type 07 FLL.  This process carries with it its own unique federal, state and local considerations, compliance requirements and practices.  If you are interested in becoming a 07 FFL, please contact Attorney Matthew P. Trask to discuss the process.  

For more information visit Kelsey & Trask, P.C. or Holdover Consulting, LLC



Thursday, September 18, 2014

Owning an SBR - Part 2: Complying with Federal, State and Local Regulations

The National Firearms Act of 1934, in conjunction with Title II of the Gun Control Act of 1986, regulates the ownership of certain firearms, including Short Barrel Rifles ("SBR").  A Short Barrel Rifle is defined as any rifle having barrel length of under 16 inches, as measured from the face of the closed bolt to the muzzle, and/or having an overall length of under 26 inches.

This is the story of how and why Kelsey & Trask, P.C. Partner and Holdover Consulting, LLC Principal Matthew Trask legally obtained an SBR.  Although this process was specific to the acquisition of an SBR, the process would be similar for any other Title II firearm.  To read how Matthew chose his SBR read our previous post: Owning an SBR - Part 1: Finding the right SBR for me.

Owning an SBR - Part 2: Complying with Federal, State and Local Regulations

To convert our DF94 into a legally owned SBR, we would next need to obtain the proper tax stamp.  Obtaining a tax stamp to own/manufacture a Title II firearm is theoretically straightforward, although a prospective SBR owner should be aware of a few regulatory considerations at the Federal, State and Local levels:

Federal Regulatory Considerations:  

The National Firearms Act imposes a statutory excise tax on the manufacture and transfer of certain firearms and mandates the registration of those firearms.  These firearms, often referred to as “Title II Firearms” or “NFA Firearms” fall into one of six categories:

a. Short Barrel Rifles
b. Short Barrel Shotguns
c. Destructive Devices
d. Machine Guns
e. Suppressors/Silencers
f. Any Other Weapons (AOW)

The manufacture of any of these types of firearms requires the purchaser or manufacturer to pay the requisite excise tax of $200.00 (or $5.00, for certain AOW’s transferred on a Form 4).  Additionally some manufacture or transfer do not require the payment of the excise tax – only registration – in certain cases, such as manufacture by a federal licensee who has paid a Special Occupational Tax or transfers pursuant to the administration of an estate.  Generally, if a nonlicensee seeks to acquire a Title II firearm, either by manufacture or acquisition from a Title II dealer, the nonlicensee will be required to pay the $200 excise tax.  Submission of registration documents is required in all cases.


The federal government also prohibits the manufacture for civilian sale of new machine guns, and the transfer of any machine gun which was not registered prior to 1986.  As before, there are some very narrow exceptions to this rule, and it is best to contact an attorney or knowledgeable NFA dealer if you are considering the purchase of a machine gun.

State Regulatory Considerations:  

Some states will limit or restrict the possession of firearms regulated by the National Firearms Act under state law.  Some states laws will ban the possession of certain NFA items outright, while other laws will ban the possession of certain NFA firearms indirectly.

For example, legislation in Massachusetts bans the possession of suppressors outright.  Short-barrel shotguns are not specifically banned, but Massachusetts does prohibit the possession of a “Sawed Off Shotgun” (a weapon, made from a shotgun that has a barrel length of less than 18 inches).  The sawed-off shotgun prohibition does not prevent the registration of all SBS’s; but it is illegal to manufacture a SBS and register it in MA on a Form 1.  A purchaser must register an SBS in Massachusetts on a Form 4, and the SBS must have originated from the original manufacturer as a Title II firearm.

In Massachusetts, machine guns are legal, but anyone seeking to obtain a machine gun must hold a MA License to Possess a Machine Gun issued by the Chief Law Enforcement Officer of the purchaser’s town of residence.  AOW’s and Destructive Devices are not specifically prohibited in MA, although a prospective buyer would need to be conversant on Massachusetts laws regarding (a) The MA Assault Weapons Ban; (b) MA laws regarding disguised firearms; and (c) Massachusetts laws regarding the possession of explosives or “infernal machines”.

Before purchasing a Title II firearm or attempting to obtain federal approval, ensure that such firearm will not violate your state's laws.

Local Regulatory Considerations:

As of September 14, 2014, if a Title II firearm is to be acquired by an individual (and not a corporation, trust, or other legal entity), the individual must obtain a law enforcement certification on the Form 1 or Form 4, as appropriate.  Such certification, by federal law, is not intended to be “discretionary” by the CLEO, but many law enforcement officers refuse to sign the certification, thereby preventing the purchaser from obtaining a Title II firearm.  It should be noted that presently purchases of a Title II firearm by a trust, corporation or LLC do not require (a) CLEO certification; (b) fingerprinting of the intended possessor of the firearm; and (c) the submission of photographs to the ATF.

Assuming that you have met all Federal, State and Local requirements, you may now begin the process to make and register your NFA firearm with the following important notes:

NOTE on Form 1:  In the case of registration on an ATF Form 1 (Application to Make and Register a Firearm), you MUST have the approved Form 1 back from ATF with a cancelled tax stamp BEFORE you manufacture your Title II Firearm.

NOTE on Form 4:  In the case of registration on an ATF Form 4 (Application for Tax Paid Transfer and Registration of Firearm), you MUST have the approved Form 4 back from ATF with a cancelled tax stamp BEFORE you take possession of your Title II Firearm.

Essentially, the NFA registration process is done before a firearm is manufacturer or changes hands. Transferring a Title II firearm without an approved Form 4, or manufacturing a Title II firearm without an approved Form 1 is a violation of federal law.

Therefore, although you may be in possession of certain components for your NFA firearm (a lower receiver or host gun for a Title II conversion), that firearm must remain in Title I configuration until you receive your approved registration documents.  Since the Form 1 will request that you provide certain information regarding the firearm, such as overall length, barrel length and caliber, it will be necessary for you to do a bit of research and planning to determine the specifications of the firearm you intend to build.  Remember that the dimensions disclosed in the Form 1 are for the configuration of the final Title II firearm.

Our Form 1 experience:

The appropriate document for manufacturing an NFA firearm from an existing Title I firearm is ATF Form 1 (5320.1).  The form can be downloaded in .pdf form from the ATF’s website, or completed electronically on via the ATF’s eForms system.  If possible, I highly recommend utilizing the ATF eForms system.  Electronically-submitted Form 1’s have been approved in as little as 25 days, while “hard copy” forms take more than six months and 8-12 month waits are not uncommon.

We submitted and Electronic Form 1 for manufacture (conversion) of our SBR, and received approval in thirty-nine days.

The completion of the Form 1 itself is fairly straightforward.  However, forgetting to attach certain documentation will result in the rejection of your Form 1.  In Massachusetts, this additional documentation which should be filed as part of your Form 1 is:

1. All Applications - Copy of your License to Carry Firearms (LTC)
2. If an Individual – 2”x2” photograph
3. If an Individual – Completed Fingerprint Cards, in duplicate
4. If an Individual – Completed Law Enforcement Certification
5. If a Corporation or Trust – Copy of Trust or Articles of Organization
6. All applications – Payment of $200.00

If you would like any assistance regarding the completion of your Form 1 or guidance on the purchase and registration of a Title II firearm, please contact Attorney Matthew Trask at 508.655.5980.


Thursday, August 7, 2014

Good Idea, Bad Idea - Cosigning a Loan

There are many good reasons why you may want to cosign a loan.  Some typical examples include helping a child obtain their college education by co-signing student loans, or assisting your spouse in purchasing a car. With any good idea, however, a small difference in the situation can make it a very bad idea.

Many people are unaware of the consequences of cosigning a loan, and in many many instances cosigning may be a very bad idea.  Take just the two examples described above:  If your child is unable to find a job after college and therefore unable to pay their student loan, that loan will be your responsibility.  If you and your spouse separate and he or she stops paying their car loan, your credit will be affected as well (even if they still have the car).

In these previous three posts we explored what happens when a cosigner or the primary borrower on a loan declares bankruptcy:

What happens to my Cosigner if I file for Bankruptcy?

I co-signed a loan and the primary borrower has filed for bankruptcy. What should I do to protect myself?

I am the primary borrower on a loan and my cosigner has filed for bankruptcy. What should I do to protect myself?

The short answer is simple: IF YOU SIGN A PROMISSORY NOTE, YOU HAVE A RESPONSIBILITY TO PAY THAT LOAN.  

By the numerous comments and questions we receive on all three of those posts it is obvious that many cosignors don't realize how serious this obligation is when they signed the loan.  Many people feel that it should matter that they don't have access to the collateral (such as a house or car) or that they don't have a relationship with the primary borrower anymore.  These are all the inherent risks in co-signing a loan and it doesn't matter to the lender.  If you cosigned a loan, you agreed to pay the money back if the other person doesn't, regardless of the circumstances.

If it isn't paid on time your credit will be affected.  If it isn't paid at all, the lender can sue you for the funds.  If the primary borrower files for bankruptcy and the debt is discharged so that they no longer owe it, you still do!

Cosigning a loan is not something that should be taken on lightly.  There are often good reasons to do it, but you should also consider all of the reasons why you might not want to.  In short, if you can't pay back the loan yourself, then you'd better be 100% positive that the primary borrower will pay it back.  If the lender was convinced of that, then the primary borrower wouldn't need a co-signor in the first place.


Wednesday, July 23, 2014

Owning an SBR - Part 1: Finding the right SBR for me.

The National Firearms Act of 1934, in conjunction with Title II of the Gun Control Act of 1986 (codified at Title 26 United States Code, Chapter 53, Internal Revenue Code) ("NFA") regulates the ownership of certain firearms, including, Short Barrel Rifles ("SBR"), Short Barrel Shotguns, Machine Guns, Destructive Devices, Suppressors and AOW's (Any Other Weapon).

A Short Barrel Rifle is defined as any rifle having barrel length of under 16 inches, as measured from the face of the closed bolt to the muzzle, and/or having an overall length of under 26 inches.  This is the story of how and why Kelsey & Trask, P.C. Partner and Holdover Consulting, LLC Principal Matthew Trask legally obtained an SBR.  Although this process was specific to the acquisition of an SBR, the process would be similar for any other Title II firearm.

Owning an SBR - Part 1: Finding the right SBR for me.

Ever since I watched Bruce Willis as John McClane dispatching eastern-European terrorists over the side of the Nakatomi Plaza, I’ve had a soft spot for the MP5.  I wanted one.  With the proper licenses, I could even own one in Massachusetts.  Unfortunately, a transferrable, fully-automatic Title II MP5 will cost upward of $22,000.00.

The next best thing was the semi-automatic carbine version of the MP5 produced by Heckler & Koch and imported into the United States from 1982-1991.  A total of 15,633 HK94 carbines came overseas from Oberndorf am Neckar, the last one in 1991.  HK94 prices have risen steadily, and even a semi-automatic version can fetch close to $5,000.00 today.

After HK stopped importing the semi-automatic derivatives of the MP5, a number of small builders and manufacturers sprang up and started producing clones of the HK94 and HK89.  At about the same time, license-built copies produced in other countries were imported to the U.S.

Early models utilized surplus HK parts which were permitted to be imported, but as those supplies dried up, some builders started manufacturing their own components, often with varying amounts of tolerance and degrees of success.   Put another way, there were good clones and bad clones.  Good builders and bad builders.  High volume guys and low volume guys.  It was tough to tell the difference.  If you chose your builder correctly, you could get a near-perfect clone for around half of what a “genuine” HK cost.  If you chose poorly, you could get a two thousand dollar paperweight.

Recently I was discussing these issues with the owner of my local gun shop, who is also a Title II/Class 3 dealer in Natick, MA.  He immediately suggested I consider a DF94, an MP5/HK94 clone build by Dave Getz of DJ Getz Firearms Co. I looked at one of the new DF94’s he had, and had to agree it was a very well-built, built-to-spec HK clone.  The welds were clean, the machining on the bolt and bolt carrier were smooth and the fit and finish were very nice.  As an added benefit, the DF94 shipped with a tungsten filled bolt carrier and other upgrades, making a more than acceptable sear host if I ever (legally!) wanted to down the road.

A day or so after I picked up the rifle, I had a few questions.  I emailed Dave Getz with a few questions over components and parts compatibility.  Not 15 minutes later, Dave himself called me with an answer to my questions.  We chatted about our affinity for Teutonic steel, rapid-acquisition optics and the direction gun laws seem to be heading at a state and federal level.  Dave didn’t have to call me to answer my questions, but he did.  You don’t see that level of customer service anywhere.  That conversation and 600 flawless rounds later, I was a very happy customer.

There was, of course, one problem.  The National Firearms Act requires that a rifle have a barrel length of 16 inches, and an overall length of 26 inches.  The DF94 I was now the proud owner of had a faux suppressor pinned and welded on the end of the muzzle to bring the overall barrel length of the rifle to over 16 inches.  Detective McClean’s MP5 had a barrel of just under 9 inches, so some work would need to be done.  Time for an SBR.

Part II will discuss the National Firearms Act and the process for legally manufacturing a Short Barrel Rifle as well as our experience Navigating the ATF's E-Forms System.

Part III will involve dragging the Kelsey & Trask, P.C. team out to the range.

Thursday, June 26, 2014

What are the Restrictions on a Massachusetts Dealer Selling a Handgun?

Before a licensed dealer in Massachusetts can transfer a handgun they have to answer four questions:

1. Is the buyer a Massachusetts resident or a federally licensed dealer in another state?
2. Does the buyer have a License to Carry, Class A, Large Capacity?
3. Did the buyer pass the NICS background check, if required?
4. . Is the handgun “Mass Complaint?” (i.e. listed on the EOPSS Approved Firearms Roster and compliant with the Attorney General's regulations)

If the answer to all of these questions is "yes", then the handgun transfer is legal in Massachusetts.  However, if the answer to any of these questions is "no", read on, because there are some exceptions described further below.  

Question 1: Is the buyer a Massachusetts resident or a licensed dealer in another state?

There is a federal restriction on interstate transfers of handguns.  This means that handguns can only be transferred between license dealers or manufacturers across state lines.  When selling to an individual, dealers can only sell to residents of their state. 18 U.S.C. 922(a)(3) and (5), 922(b)(3), 27 CFR 478.29 and 478.30.

Exceptions:  The only exception is that a dealer may "return[ ] a firearm or replacement firearm of the same kind and type to a person from whom it was received" 18 U.S.C. 922(a)(2), even if the transferee resides in a different state.  Otherwise a violation of this rule is punishable by up to five years in federal prison. 18 U.S.C. 924(a)(1)(d).

Question 2: Does the buyer have a License to Carry, Class A?

An LTC/A in Massachusetts permits the holder to possess and concealed carry a handgun, subject to potential restrictions listed on the license. M.G.L. c. 140 s. 131(a).

Exceptions:  There are also LTC Class B and Permits to Purchase allowable under the licensing statute, but these are rarely granted. M.G.L. c. 140 s. 131(b); M.G.L. c. 140 s. 131A.  An LTC/B would entitle the holder to purchase large capacity rifles and shotguns, as well as non-high capacity handguns only. M.G.L. c. 140 s. 131(b).

Question 3: Did the buyer pass the NICS background check?

The National Instant Criminal Background Check System ("NICS") is operated by the Federal Bureau of Investigation and is used by licensed dealers to instantly determine whether a prospective buyer is federally prohibited under 18 U.S.C. 922(g) and (n) from receiving or possessing a firearm.  The NICS check is mandated by the Brady Handgun Violence Prevention Act (Brady Law) of 1993 See, 18 U.S.C. 922(t), 27 C.F.R. 478.102.

Exceptions: Limited.  Firearm transfers are exempt from the requirement for a NICS check in three situations. These include transfers: (1) to buyers having a State permit that has been recognized by ATF as an alternative to a NICS check; (2) of National Firearms Act weapons approved by ATF; and (3) certified by ATF as exempt because compliance with the NICS check requirement is impracticable.  18 U.S.C. 922(t), 27 CFR 478.102(d) See also, 27 C.F.R. 478.11.  Also, Transfers of curio or relic firearms to federally licensed curio and relic collectors are not subject to the requirements of the Brady law.  See also, 27 C.F.R. 478.124 (Form 4473 and NICS check not required if upon the return of a firearm delivered to a gunsmith for the sole purpose of repair or customizing when such firearm or a replacement firearm is returned to the person from whom received.)

Question 4: Is the handgun Mass Complaint?

Handguns which are currently "Mass Compliant" are those which appear on the Approved Firearms Roster and comply with the Attorney General regulations.  These represent the majority of handgun transfers between Massachusetts dealers and residents.  However, there are some complicated exceptions which allow for transfers of handguns that are not otherwise "Mass Compliant."

Exceptions: There are three primary exceptions to the requirement that a handgun be Mass Compliant:

Exception: Handguns Documented in MA prior to October 21, 1998 - Any Handgun where the owner can show paperwork (such as an FA-10 form) showing that the handgun was lawfully owned or possessed under a Massachusetts license before October 21, 1998, the transfer of that handgun by a Massachusetts licensed dealer is completely exempt from AG and EOPSS regulations.  It should be noted that there is no requirement that the handgun remain or be continuously present in Massachusetts since October 21, 1998; only that the owner can show it was registered in Massachusetts prior to October 21, 1998. M.G.L. c. 140 s. 123, 940 C.M.R. 16.09.  See also M.G.L. c. 93A s. 2(c).

Exception: Handguns on Approved Firearms Roster and Manufactured prior to October 21, 1998 - Handguns can be sold which appear on the Approved Firearms Roster, but are exempt from the Attorney General’s regulations by virtue of having been manufactured before October 21, 1998.  This category pertains mainly to Glock handguns.  Note that there is no requirement here that the handgun be registered in Massachusetts prior to October 21, 1998, only that it was manufactured before that date.  M.G.L. c. 140 s. 123, 940 C.M.R. 16.09.  See also M.G.L. c. 93A s. 2(c).

Exception: Handguns on Approved Firearms Roster sold to Law Enforcement Officers - Handguns which appear on the Approved Firearms Roster when the buyer is a law enforcement officer exempts the dealer from the Attorney General’s restrictions, but not M.G.L. c. 140 s. 123 requirements.  In this case it doesn't matter when the handgun was manufactured, only that the handgun appears on the Massachusetts Approved Firearms Roster. M.G.L. c. 140 s. 123, 940 C.M.R. 16.09.  See also M.G.L. c. 93A s. 2(c).


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