The proposal is long, 20 pages, and a lot of traps and inconsistencies are hidden in it.
I am starting a series of articles analyzing this proposal, and will forward all of them as my public comment to this proposal.
Even if I do not live in New York State anymore, I continue to pay property taxes in that state which feed the work of prosecutors and police, so I do have a say in the matter, as a taxpayer.
Moreover, New York does not restrict public comment only to residents of New York state.
The very first problem that jumps to mind is the lack of transparency in:
- how the body that proposed this rule - the permanent New York Justice Task Force - was formed, without any input from the public, taxpayers, voters and consumers of legal services;
- how it convened - without following the Public Meetings Law, without notice to the public or opportunity to be heard, behind closed doors;
- how it formed its committees and subcommittees;
- how and from whom the Task Force solicited "recommendations".
- no say in the composition of the Task Force;
- no say in the work of the Task Force;
- no notice as to meetings of the Task Force;
- no opportunity to be present at those meetings or provide their own input to the work of the Task Force -