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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

JENNIFER VANDERSTOK; 

MICHAEL G. ANDREN; 

TACTICAL MACHINING, LLC, a limited liability 

company; and 

FIREARMS POLICY COALITION, INC., a nonprofit 

corporation,

 Plaintiffs,

and

Not An LLC d/b/a JSD SUPPLY,

 Applicant in Intervention,

 v.

MERRICK GARLAND, in his official capacity as 

Attorney General of the United States; 

UNITED STATES DEPARTMENT OF JUSTICE; 

STEVEN DETTELBACH, in his official capacity as 

Director of the Bureau of Alcohol, Tobacco, Firearms 

and Explosives; and 

BUREAU OF ALCOHOL, TOBACCO, FIREARMS 

AND EXPLOSIVES,

 Defendants.

 Civil Action No. 4:22-cv-691-O

NOT AN LLC DBA JSD SUPPLY’S

[PROPOSED] MOTION FOR PRELIMINARY INJUNCTION

Pursuant to Federal Rule of Civil Procedure 65, Northern District of Texas Local Civil 

Rule 7.1, and 5 U.S.C. § 705, Intervenor-Plaintiff Not an LLC, dba JSD Supply (hereafter, “JSD 

Supply”), through its undersigned counsel, move this honorable Court for a nationwide 

preliminary injunction prohibiting Defendants and their officers, agents, servants, and employees 

Case 4:22-cv-00691-O Document 151 Filed 01/05/23 Page 1 of 3 PageID 2845
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from implementing and enforcing the provisions established and amended by the Department of 

Justice and Bureau of Alcohol, Tobacco, Firearms, and Explosives’ Final Rule entitled Definition 

of “Frame or Receiver” and Identification of Firearms (“Final Rule”), 87 Fed. Reg. 24,652 (Apr. 

26, 2022), and/or to postpone the effective date of the Final Rule.

Alternatively, JSD Supply requests that the Court issue a determination that JSD Supply is 

entitled to the same injunctive relief and protections granted to Tactical Machining in the Court’s 

September 2, 2022 Order, ECF No. 56. Further and alternatively, JSD Supply requests that the 

Court enjoin Defendants’ ability to rescind the lawful classification letter issued to JSD Supply by 

ATF on November 21, 2017, submitted with JSD Supply’s accompany Brief, in order for JSD 

Supply to lawfully continue selling non-regulated receiver blanks with non-regulated tools, jigs, 

and instructions as it did prior to the Final Rule’s effective date. 

JSD Supply’s counsel has conferred with counsel for Defendants, who oppose the relief 

requested herein. Counsel for Plaintiffs take no position as to this motion.

In support of this Motion, JSD Supply concurrently files its Brief in Support of Proposed 

Motion for Preliminary Injunction along with supporting documentation pursuant to Northern 

District of Texas Local Civil Rule 7.1(d). 

DATED this 5th day of January, 2023.

Respectfully submitted,

/s/ Matthew J. Smid

MATTHEW J. SMID

TX Bar No. 24063541

ATTORNEY AT LAW

301 Commerce Street, Suite 2001

Fort Worth, Texas 76102

Phone: (817) 332-3822 Phone

Fax: (817) 332-2763 Fax

matt@mattsmidlaw.com

Case 4:22-cv-00691-O Document 151 Filed 01/05/23 Page 2 of 3 PageID 2846
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J. MARK BREWER

Texas Bar No. 02965010

BREWER & PRITCHARD, P.C.

800 Bering Dr., Suite 201

Houston, TX 77057 

Phone: (713) 209-2910

brewer@bplaw.com

Attorneys for proposed Intervenor-Plaintiff Not an 

LLC, dba JSD Supply

CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1

On December 20, 2022, the undersigned contacted all counsel for Plaintiffs and 

Defendants regarding this motion. On December 22, 2022, Martin M. Tomlinson, counsel for

the Government, emailed counsel for the moving party that the Government opposes this Motion. 

On January 5, 2023, Zhonette Brown, counsel for Plaintiffs, advised Plaintiffs take no position 

with regard to this motion.

/s/ J. Mark Brewer

J. Mark Brewer

Case 4:22-cv-00691-O Document 151 Filed 01/05/23 Page 3 of 3 PageID 2847