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Our Sport is Under Attack Again

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  • Registered Users Posts: 4,772 ✭✭✭meathstevie


    Grizzly 45 wrote: »
    OK here goes;
    The ban of magazines with a capacity above 20 rounds in short firearms,and 10 rounds in long firearms,and the banning of firearms with a "length[???]" of 60 cms with a folding stock[1] and the banning of former select fire firearms that have been converted to semi auto only is both farught with constitutional pitfalls under Article 46 of the Irish constitution and under Article 14 of the European Charter of Human Rights.As the Irish constitution in this article grauntees a citizens right to posses private property,and persue a livly hood,and shall only be deprived of it save under the common good,but to which a citizen has remedy in law to apply for compenation for their "property.Which is not specified in laws as to what property is defined as

    Article 14 of EUCHR.States that where property that was legal and peacefully enjoyed by any EU citizen,and a state makes its possesion illegal,it must recompense the citizen to market value on a good day,before it was made illegal,and within a timely manner.

    Therefore as the SI now stands on those points,it is a clear intent to confiscate such items or deprive Irsh gunowners of their use and enjoyment of legally held firearms and accessories.
    As it now stands also,the owner is realistically only left with surrender without recompense.
      As these items are now CAT A [prohibited] under the EU directive,they cannot be exported within the EU to another EU state for sale. Nor can they be exported to the USA,as there is a prohibition on importing high capacity mags under the arms control act,and of "machine guns" under the Mc Clure /Volkmer act 1986 Nor can they be exported to any other country,as Ireland is a signtory of various UN arms export treaties that prohibit "military arms and dual use equipment" from being exported from the Republic Were it even possible to export these items,it is impossible to do so in the time frame of 31 calender days for the mags and now 190 calender days for the arms.As the paperwork for the Dept of both Justice and AGS is simply overwhelming.Each individual firearm and magazine must require an export and corrosponding import certificate. Considering most staff would also be on vacation handling this work possible,it is a impossibility to shift the mags out in this timeframe. There has been no public announcement as to this SI[,and many are still utterly unaware of this new SI and requirements.Not everyone follows social media in the shooting community,so they are in the utter dark of these changes. There is no accurate count of these types of guns or mags here in the ROI,Gusstimates,put the number of guns as below 60 and greater than 20.The mags could be possibly more than 50 and less than 800 There seems to be no consideration given to the various " escape hatches" in the EU directive as to grandfathering these types of firearms,and magazines by the Irish govt for some reason Such as the rendering incapble of magazines to hold either 20 or 10 shots respectively.There is precedent to do such under Irish firearms laws, Ref the .22 pistol mags renderd to 5shots,and the directive allows nations to transpose this directive into national firearms laws as they see fit,as well as grandfathering said firearms to the national legal pool of firearms.
      What can the Govt do to sort this out? Easiest. Add an addendum to the legislation grandfathering said rifles,and mags like the CF handguns to a national pool of restricted rifles,that may be liscensed by anyone with a restricted liscense.As it will be impossible to aquire such a surplus rifle in the EU anymore,as all future surplus military and police fiream stock will now be destroyed by the respective national govts under this directive.These rifles have suddenly also increased in value to their owners as well. Easy. Add an addendum on the mags that,if they were imported before Sept 2018,they are hereby grandfatherd,OR they may be renderd incapable of holding more than 20 or 10 shots respectively.Irrespective of magazine body size. On the less than 60 cm firearms,that if the folding stock is permantly pinned in an extended position,or replaced with a solid stock.AND/OR a muzzle device is permantly afixed to the barrel to bring it above the 60 cms length it is no longer a CAT A firearm and may be moved to CAT B10 Messy Allow said firearms holders,if practicable to their specific model the option of replacing their recivers and/or fire control parts,with civillian only semi auto recivers and fire control parts,and barrels,and surrendering the converted former select fire parts and recivers,and barrels and re issuing the liscenses then as CAT B firearms,as they are now civillian firearms with same serial numbers made with some non pressure bearing parts or select fire recivers, surplus parts.[Germany has a precedent to do this and does sell such firearms]If not practible,the state will have to compensate the owner,and GRAUNTEE that the new issued liscense WILL NOT fall foul of the Amendment Francis Fitzgerald brought in.That post 2017 all future semi auto liscenses stand revoked ,as this sI has not been enacted,and these were previously legal liscenses issued before 2017 Hideoulsly messy. Ignore any and all suggestions.Demand confiscation,Expect legal HC challenge from individuals and organisations,drag this thru courts,fork out taxpayers money in a "gun buyback scheme" as the media wil brand it,lose the good will of a group that did vote for you five years ago because of FG's fair play and listening to Irish shooters in the Dail hearings,in an upcoming election within the next 6months,and with a crisis facing the state on Oct 31st the equivilent of the Emergency"

    The law is very clear what constitutes one's property, it's the material and immaterial goods you own. Your socks and your house are both your property.


  • Registered Users Posts: 335 ✭✭yubabill


    As regards the handgun ban, I heard a senior Garda on the radio Thursday, describing the gangland situation as being the worst it's ever been.

    So it's very clear to any objective observer (and there are exactly none, outside the shooting community) that the handgun ban has had zero effect on gun crime, given that most handgun owners were allowed keep their firearms after the ban.

    On the new SI;

    1. I see the NARGC have concerns they will be pressing - I imagine the main one is the new requirement for safe storage of all firearms, including shotguns.

    2. While there are issues for many, the main take-home from this SI is that there is no general ban of C/F S/A long arms.


  • Registered Users Posts: 14,951 ✭✭✭✭Grizzly 45


    1. I see the NARGC have concerns they will be pressing - I imagine the main one is the new requirement for safe storage of all firearms, including shotguns.

    What is their big gripe?That their members must put their guns in a slip when travelling by car and the ammo in a locked receptacle as well to prevent casual theft? SOP with European hunters for the last 20 years.
    Be more concerned that you werent consulted y DOJ and save your ammo (pun intended) for the upcoming lead ban.


    2. While there are issues for many, the main take-home from this SI is that there is no general ban of C/F S/A

    "You're welcome Irish gunowners!"

    Firearms United Network.

    "If you want to keep someone away from your house, Just fire the shotgun through the door."

    Vice President [and former lawyer] Joe Biden Field& Stream Magazine interview Feb 2013 "



  • Registered Users Posts: 11,758 ✭✭✭✭BattleCorp


    I've a question regarding the new S.I.

    If I buy a gun or parts that were imported into the EU today (after September 14, 2018), it's clear that the essential components need to be marked. Easy when it's a complete gun but what's the story with guns made from different parts? Say an F Class gun? The receiver will come with one serial number and most likely the barrel will come with a different serial number as it won't be from the same manufacturer.

    Does this serial number have to match the serial number on the licence or can it be any unique number? The only number recorded on the licence is the number on the receiver. So now I potentially have a gun with two different serial numbers.

    And then what happens when you need to buy a new barrel or two guys swap barrels? Or if you have a spare barrel? There is only a register of who has what serialised receiver (licencing system). There is no register anywhere citing who has what numbered parts and such a register would be completely unworkable.

    Would I be in breach of this SI by having a gun with several different serial numbers inscribed on it?


  • Registered Users Posts: 14,951 ✭✭✭✭Grizzly 45


    Good question.
    Another one to add to the list.

    "If you want to keep someone away from your house, Just fire the shotgun through the door."

    Vice President [and former lawyer] Joe Biden Field& Stream Magazine interview Feb 2013 "



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  • Moderators, Sports Moderators Posts: 28,457 Mod ✭✭✭✭Cass


    BattleCorp wrote: »
    If I buy a gun or parts that were imported into the EU today (after September 14, 2018), it's clear that the essential components need to be marked. Easy when it's a complete gun but what's the story with guns made from different parts? Say an F Class gun? The receiver will come with one serial number and most likely the barrel will come with a different serial number as it won't be from the same manufacturer.
    Every action i've owned or bought has had a serial number. This is what i used for the license.

    For the barrel i use the action serial number simply because not one barrel i have ever bought/imported has had a serial number. On the end of each barrel blank is the caliber, twist rate and manufacturer stamp but the gunsmith always cuts this bit off. Two reason, i'm told, for record keeping of the barrels imported and record of which barrel went to which build.

    However the barrel itself never had a manufacturer stamp, serial number, even caliber marked on it.

    So in short, at least for rifles barrels, its going to be either a non existant issue or one that affects such a tiny percentage as to not be a problem (i only include the latter because obviously i've never seen every brand of rifle barrel)
    Would I be in breach of this SI by having a gun with several different serial numbers inscribed on it?
    When it comes to buying a "pre-fit" barrel from a manufacturer like say Remington, Savage, etc. where there may be a serial number on it then it does cause a problem.

    You can have a spare barrel for your firearm so long as the caliber does not change. The new SI says it must be marked. However if your license is for action "ABCDEF" and barrel "ABCDEF" but your spare barrel is marked "GHIJKLM" then the SI does not address what to do in the cases of spare barrels of the same caliber.

    Should you remove the serial number under which it was imported and replace it with the one you are currently licensed on or do you "add" it to your current license as a second barrel?

    Does PULSE allow for multiple serial numbers on the one license? I think not, but stand to be corrected.
    Forum Charter - Useful Information - Photo thread: Hardware - Ranges by County - Hunting Laws/Important threads - Upcoming Events - RFDs by County

    If you see a problem post use the report post function. Click on the three dots on the post, select "FLAG" & let a Moderator deal with it.

    Moderators - Cass otmmyboy2 , CatMod - Shamboc , Admins - Beasty , mickeroo



  • Moderators, Sports Moderators Posts: 28,457 Mod ✭✭✭✭Cass


    Grizzly 45 wrote: »
    2. While there are issues for many, the main take-home from this SI is that there is no general ban of C/F S/A

    "You're welcome Irish gunowners!"

    Firearms United Network.

    Page 22 of the revised Garda Commissioner's Guidleines:
    Issuing persons and applicants alike should be mindful that, on 18th September 2015, the Minister for Justice and Equality announced that any new restricted firearm certificates for centre fire semi-automatic rifles, granted between that date and the enactment of proposed legislation banning the future licensing of these types of firearms, shall stand revoked.
    I know its the Commissioner's Guidelines, and while based in law there is no current law banning them, but the self imposed ban that seems to be occurring is wrong and all that, but just be mindful that the issue is not gone, it's not forgotten about, and if enacted will cause a headache for those after Sept 2015.
    Forum Charter - Useful Information - Photo thread: Hardware - Ranges by County - Hunting Laws/Important threads - Upcoming Events - RFDs by County

    If you see a problem post use the report post function. Click on the three dots on the post, select "FLAG" & let a Moderator deal with it.

    Moderators - Cass otmmyboy2 , CatMod - Shamboc , Admins - Beasty , mickeroo



  • Moderators, Sports Moderators Posts: 28,457 Mod ✭✭✭✭Cass


    @ Grizzly_45 - I'm not going to quote the whole post, but your list of reasons the SI is a problem is all about the mag ban. Not nit picking, being a smart arse, nor am i getting at you but is that the only issue?
    Forum Charter - Useful Information - Photo thread: Hardware - Ranges by County - Hunting Laws/Important threads - Upcoming Events - RFDs by County

    If you see a problem post use the report post function. Click on the three dots on the post, select "FLAG" & let a Moderator deal with it.

    Moderators - Cass otmmyboy2 , CatMod - Shamboc , Admins - Beasty , mickeroo



  • Registered Users Posts: 14,951 ✭✭✭✭Grizzly 45


    Cass wrote: »
    @ Grizzly_45 - I'm not going to quote the whole post, but your list of reasons the SI is a problem is all about the mag ban. Not nit picking, being a smart arse, nor am i getting at you but is that the only issue?


    At the moment it is ASFIK the only fightable issues....

    Does having critical components marked on firearms post 2018 from outside the EU affect our use and enjoyment on a daily basis?

    Does Irish gunsmiths having to put their name and details on one of thier creationns affect us as users?Or them more so if some one in the EU is suddenly wearing a bolt in their forehead and the gun looks like somthing Wily E Coyote bought from an ACME catlouge after firing?:p It';s not just EU paranoia about ghost guns,[which this wont really affect anyway] but also product liability?

    People are losing their sht about these storage requirements and transport requirements.There is NO NEED to turn your car into a mobile bank vault,as some [notably some gundealers] who want to sell you a car safe that is utter overkill when a gunslip with a 99cent padlock and putting your ammo in a locked duffle bag covers you legally, with one in the boot with one in the back seat.With BOTH keys on your car ignition key ring. That makes it impossible to access gun or ammo without physically stopping the car to do so.

    How difficult is it to put your ammo in a locked press or chest of drawers,room,ammo box etc?Which was always issued in the Garda recommendations of good firearms ownership?

    This is SOP for EU shooters for the last 20 years folks,and we all know ,AGS included ,this will only prevent casual theft not someone sophisticated enough to bypass immobilisers and modern car alarms.Even your rear inbuilt 2 thousand biometric gun safe wont survie these people. I've been doing this myself since year dot,so me,personally,I cant see how you could argue against good gun house keeping?

    Maybe I'm missing somthing in the rest of this SI,but what is the great burden on regular non restricted shooters???

    I should also mention,that this SI has wiped out in one fell swoop,every gun dealer that is also a film and movie prop supplier of firearms to the Irish film industry! The majority of modern firearms are or were former select fire guns,irreapbly converted to blamk firing!So guess in future any Irish action films will have the heros and villans running about with Airsoft,while crap sound effects are added?
    And any of you lads who do reenactment from ww2 to today...Hand em in too!! You blank firing MP40,STEN ,etc is now a CAT A prohibited too.
    Maybe the FCP will be voicing these folks concerns too???

    "If you want to keep someone away from your house, Just fire the shotgun through the door."

    Vice President [and former lawyer] Joe Biden Field& Stream Magazine interview Feb 2013 "



  • Registered Users Posts: 14,951 ✭✭✭✭Grizzly 45


    Cass wrote: »


    I know its the Commissioner's Guidelines, and while based in law there is no current law banning them, but the self imposed ban that seems to be occurring is wrong and all that, but just be mindful that the issue is not gone, it's not forgotten about, and if enacted will cause a headache for those after Sept 2015.

    Yup,and thats why I mentioned this in the "messy" part of my previous post.


    "Allow said firearms holders,if practicable to their specific model the option of replacing their recivers and/or fire control parts,with civillian only semi auto recivers and fire control parts,and barrels,and surrendering the converted former select fire parts and recivers,and barrels and re issuing the liscenses then as CAT B firearms,as they are now civillian firearms with same serial numbers made with some non pressure bearing parts or select fire recivers, surplus parts.[Germany has a precedent to do this and does sell such firearms]If not practible,the state will have to compensate the owner,and

    GRAUNTEE that the new issued liscense WILL NOT fall foul of the Amendment Francis Fitzgerald brought in.That post 2015 all future semi auto liscenses stand revoked ,as this sI has not been enacted,and these were previously legal liscenses issued before 2015

    "If you want to keep someone away from your house, Just fire the shotgun through the door."

    Vice President [and former lawyer] Joe Biden Field& Stream Magazine interview Feb 2013 "



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  • Registered Users Posts: 335 ✭✭yubabill


    Cass wrote: »
    Page 22 of the revised Garda Commissioner's Guidleines:


    I know its the Commissioner's Guidelines, and while based in law there is no current law banning them, but the self imposed ban that seems to be occurring is wrong and all that, but just be mindful that the issue is not gone, it's not forgotten about, and if enacted will cause a headache for those after Sept 2015.

    As we know, an Irish solution to an Irish (non-)problem.

    This fudge probably works better than actual legislation.


  • Registered Users Posts: 4,772 ✭✭✭meathstevie


    Grizzly 45 wrote: »
    Yup,and thats why I mentioned this in the "messy" part of my previous post.


    "Allow said firearms holders,if practicable to their specific model the option of replacing their recivers and/or fire control parts,with civillian only semi auto recivers and fire control parts,and barrels,and surrendering the converted former select fire parts and recivers,and barrels and re issuing the liscenses then as CAT B firearms,as they are now civillian firearms with same serial numbers made with some non pressure bearing parts or select fire recivers, surplus parts.[Germany has a precedent to do this and does sell such firearms]If not practible,the state will have to compensate the owner,and

    GRAUNTEE that the new issued liscense WILL NOT fall foul of the Amendment Francis Fitzgerald brought in.That post 2015 all future semi auto liscenses stand revoked ,as this sI has not been enacted,and these were previously legal liscenses issued before 2015

    And where would you hypothetically stand if you owned a self cocking magazine fed rifle with a manually operating spring detent to let the bolt slot back into battery while picking up a cartridge from the magazine. Definitely no longer a semi-auto as the cycle is interrupted and requires manual intervention to complete.

    The time difference to complete the cycle would be fractions of a second but the gun would not operate as a semi-auto.


  • Registered Users Posts: 14,951 ✭✭✭✭Grizzly 45


    Manually Actuated Release System.[MARS]...
    You'd be in "here be dragons!" country.As it is a totally unknown system to the Irish firearms legislation. Dunno if the Brits can even build them anymore either.But it is a neat work around the UK semi auto ban,and they were expensive enough too.

    "If you want to keep someone away from your house, Just fire the shotgun through the door."

    Vice President [and former lawyer] Joe Biden Field& Stream Magazine interview Feb 2013 "



  • Registered Users Posts: 11,191 ✭✭✭✭Nekarsulm


    "Gun Enthusiast" is now officially a code for "criminal", in the minds of the Press anyway.

    https://mobile.twitter.com/Independent_ie/status/1168003071877664770

    Now it remains to be seen what the actual facts of the case are, the lad could have taken gun parts or ammo from the station or during a search, but the paper has passed judgement on him (and you) anyway.


  • Registered Users Posts: 13,287 ✭✭✭✭kowloon


    On the marking of non-EU imported guns, does this apply to everything and is there going to be a standard to the marking? I'm thinking of all the horrible US importation markings that mess up the finish and devalue the guns. Does someone have to go bashing some nasty markings into something covered in gold inlay? Will it apply to antiques?
    Nekarsulm wrote: »
    "Gun Enthusiast" is now officially a code for "criminal", in the minds of the Press anyway.

    Drug enthusiast :D


  • Registered Users Posts: 435 ✭✭Brontosaurus


    Nekarsulm wrote: »
    "Gun Enthusiast" is now officially a code for "criminal", in the minds of the Press anyway.

    https://mobile.twitter.com/Independent_ie/status/1168003071877664770

    Now it remains to be seen what the actual facts of the case are, the lad could have taken gun parts or ammo from the station or during a search, but the paper has passed judgement on him (and you) anyway.

    From the article it sounds like he was licensed and had more ammo than the license allowed?


  • Registered Users Posts: 6,576 ✭✭✭garv123


    How do I get my 1000 Shotgun shells from the Shop to the house? Does locking the boot count?

    How do couriers ship ammo?


  • Registered Users Posts: 11,191 ✭✭✭✭Nekarsulm


    garv123 wrote: »
    How do I get my 1000 Shotgun shells from the Shop to the house? Does locking the boot count?

    How do couriers ship ammo?

    Lock the boot.
    Couriers just bung them in the back with everything else.
    After all, lots of their parcels would be worth far more than a slab of cartridges, so its always locked anyway.


  • Registered Users Posts: 1,524 ✭✭✭grassroot1


    garv123 wrote: »
    How do I get my 1000 Shotgun shells from the Shop to the house? Does locking the boot count?

    How do couriers ship ammo?

    One box at a time, under armed guard with apache gunships for cover,get a boy scout to help you across the road, wear the correct PPE, have a signed note from your parents, collect two hundred euro and do not pass go.:D
    Do what you always done its bo%$&x


  • Registered Users Posts: 11,191 ✭✭✭✭Nekarsulm


    garv123 wrote: »

    How do couriers ship ammo?

    The courier is a lot more likely to leave them propped up against your front door, or thrown into the local Centra, than you are!


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  • Registered Users Posts: 13,287 ✭✭✭✭kowloon


    grassroot1 wrote: »
    One box at a time, under armed guard with apache gunships for cover,get a boy scout to help you across the road, wear the correct PPE, have a signed note from your parents, collect two hundred euro and do not pass go.:D
    Do what you always done its bo%$&x

    Is it safe having a bunch of shells packed together like that? Surely it would make sense to have each in its own armoured sleeve with the primers kept separately in wet storage.


  • Registered Users Posts: 4,772 ✭✭✭meathstevie


    kowloon wrote: »
    Is it safe having a bunch of shells packed together like that? Surely it would make sense to have each in its own armoured sleeve with the primers kept separately in wet storage.

    Don’t you be giving some eejits notions....


  • Registered Users Posts: 7,835 ✭✭✭Rows Grower


    "Very soon we are going to Mars. You wouldn't have been going to Mars if my opponent won, that I can tell you. You wouldn't even be thinking about it."

    Donald Trump, March 13th 2018.



  • Registered Users Posts: 14,951 ✭✭✭✭Grizzly 45


    A specific app,for a scope that is an ITAR item,that no doubt many of us have here?:)

    "If you want to keep someone away from your house, Just fire the shotgun through the door."

    Vice President [and former lawyer] Joe Biden Field& Stream Magazine interview Feb 2013 "



  • Registered Users Posts: 7,835 ✭✭✭Rows Grower


    Grizzly 45 wrote: »
    A specific app,for a scope that is an ITAR item,that no doubt many of us have here?:)

    I put this in the wrong thread didn't I?

    Yup, I think I did.

    Sorry about that, interesting topic all the same.

    "Very soon we are going to Mars. You wouldn't have been going to Mars if my opponent won, that I can tell you. You wouldn't even be thinking about it."

    Donald Trump, March 13th 2018.



  • Registered Users Posts: 13,287 ✭✭✭✭kowloon


    Is there anywhere that gives an overview of gun laws in Europe in English? Legalspeak is incomprehensible enough without having to translate it.


  • Registered Users Posts: 107 ✭✭JohnFitz2332


    I'm guessing this has been asked on this or another thread before but I couldn't be bothered trying to find it; is there a body similar to the NRA for the EU that one can become a member of?

    Disclaimer: I am not into the NRA at all, but we do need a lobby.


  • Registered Users Posts: 280 ✭✭Mississippi.


    I'm guessing this has been asked on this or another thread before but I couldn't be bothered trying to find it; is there a body similar to the NRA for the EU that one can become a member of?

    Disclaimer: I am not into the NRA at all, but we do need a lobby.

    F. U.N.
    firearms United network


  • Registered Users Posts: 107 ✭✭JohnFitz2332


    F. U.N.
    firearms United network

    I saw that alright, but wasn't sure if it was legit or, indeed, effectual. Appears to be a one man band?


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  • Registered Users Posts: 14,951 ✭✭✭✭Grizzly 45


    I saw that alright, but wasn't sure if it was legit or, indeed, effectual. Appears to be a one man band?


    Yeah ...Very ineffectual alright:D.Came out of nowhere , started by a very peed off Pole, formed within 14 days of the Paris attacks, and within 6 months has become one of the most effective, registered and recognised EU lobby groups on the firearms scene. They were lobbying the EU parliment,for six weeks before FACE even woke up to the fact that their members would be affected. Non stop relentelss lobbying of EU MEPS.So much so that two women MEPs stood down the might of the EU 's bullying at 3;30 AM in a star chamber meeting AKA in EU speak as a "trilouge" of the insufferable Sir Peter King and Guy Verhoffstat, demanding that a UK type gun ban was the "best for the entire EU!" They were armed with information provided by a extremely tough lady from Berlin,who spent her entire downtime while having chemo thereapy,doing research on the fallacy of the EU gun control.She was so good that even the anti gun side started to use her facts and figures and research.

    The one man band has groups in ;Ireland,Germany,France,Italy,Hungary,Norway,Poland,Sweden,Finland,Assoc membership in the UK,The Czech Republic ,Slovakia,Malta,and a few others I might have forgotten. All voulenteers,keeping down day jobs and have put their own monies in the game,without a penny in return or sponsorship from the gun lobby ,as claimed by some anti gun journalists.

    FUN is also a recognised lobby group in Brussels and liscensed to conduct such activity.We alaso have the top Swedish female IPSC shooter as a spokesperson,one of the best Italian gun writing and journalist on our side,a female German gun dealer and also now have in place one of the women MEPs on the council who is not going to let the EU push the lead ban thru without a serious fight.
    Our local chapter FUN IRL or just "FUNI",is in a formative stage.It needs to be recognised by a national body so as to be able to get a more substantative voice to Irish shooters in Europe.

    Donations ,we cant accept them at the moment here as we are a non recognised body or have any liscensing to collect or solict funds...What would be more helpful right here and now would be "a few good men&women" who would muck in on assisting in lobbying,answering phones,emails and keeping the FB page and hopefully sometime ,a webpage straight and narrow.

    "If you want to keep someone away from your house, Just fire the shotgun through the door."

    Vice President [and former lawyer] Joe Biden Field& Stream Magazine interview Feb 2013 "



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