When establishing the legal document preparer program, the purpose was clearly stated: “… the need to protect the public from possible harm caused by nonlawyers providing legal services must be balanced against the public’s need for access to legal services.” ACJA 7-208(C) emphasis added. The program was established to “Protect the public through the certification of legal document preparers to ensure conformance to the highest ethical standards and performance of responsibilities in a professional and competent manner.” ACJA 7-208(C)(1)

For many Arizonans, the high costs of attorney fees are simply not affordable. They are forced by economics to represent themselves. It is impossible to maintain any legal action without legal documents. Self-represented litigants (“SRLs”), without legal training, often find it difficult to narrow down the legal issues in their matters and find and cite to relevant legal authority to resolve those issues. This makes it difficult, if not impossible for SRLs to protect their legal rights. Additionally, courts are placed in a position of deciphering the intentions of the SRLs before they can begin to consider the merits of claims. For this reason, the legal document preparer program was established to to “Prepare or provide legal documents, without the supervision of an attorney, for an entity or a member of the public in any legal matter when that entity or person is not represented by an attorney.” ACJA 7-208(F)(a) emphasis added.

After a two-year task force on increasing access to legal services and introducing the LP program, which has yet to have any certificates issued and will only include practitioners in family law at the beginning, we see a proposed change to ACJA 7-208 that will reduce access to legal services. This is at a time when the recently released 2020 Arizona Access to Justice Commission Annual Report states:

"Legal aid agencies remain overwhelmed with demand for civil legal assistance. These agencies face actual or potential loss of funding, threatening not only the timely delivery of legal services but also the capacity to administer an effective volunteer lawyer program. Quick access to useful legal information that can be understood and used by self-represented litigants (“SRLs”) remains a critical need." (p. 3) (March 2021)

The proposed ban on drafting “substantive legal motions, supporting memorandum, or appellate briefs, except that a legal document preparer may assist a client with a completion of motions in family court proceedings using the appropriate court approved motions form ” will harm the public. (The court provided motion form in Yavapai County is blank. A copy will be uploaded with these comments. It is not clear why the use of a blank form will help protect the public from harm or do anything to assist in the drafting of a legal document that is easier to produce using word processing software.) Denying access to affordable legal services to those who cannot afford an attorney is denying access to justice. Instead of having a justice system where an issue is determined on the merits, we will become a justice system where legal rights are determined by whether a person has the means to afford an attorney.

It is possible to write a substantive legal document without providing legal advice and while keeping the SRL firmly in the driver’s seat of determining what issues are relevant and what issues the SRL wishes to argue. The legal document preparer (“LDP”) may ask the client to consult with an attorney in a limited scope to determine issues and legal theory which is then used by the LDP to draft the substantive document. The proposed rule changes 7-208(F) do not even consider that an LDP can collaborate with an attorney, who is involved in a limited scope.

Furthermore, when this very same issue was brought up with the last proposed change in 2017, division staff could not provide one single instance of a consumer who had been harmed by an LDP preparing a substantive motion. The only complaints related to substantive motions were filed by judges and attorneys, who did not feel the LDP should be allowed to prepare these types of documents. There simply is no good reason for adopting this change, and a very good public policy reason to not make this change: to promote access to legal services for SRLs.

I understand the argument that “the LP can provide those services.” However, there are none at present and their scope of practice is limited to family law because that is the only specialization test available at the present time. This leaves a huge gap in access to legal services. Perhaps in time the LP program will become more viable as a solution, but at the present time it is not. To restrict LDPs in the hope that the LP program might someday provide a solution is bad public policy and leaves SRLs in a terrible situation of losing legal rights because they are not wealthy enough to afford them. We will have a system of justice for wealthy, but not for the poor. That is not justice.

7-208(E). The removal of court employees from those who can become a LDP is a mystery. Court employees are familiar with procedure and court forms. Why are they suddenly not acceptable to become LDPs? They still must pass the certification test. When we are trying to increase access to legal services, this change makes no sense.

7-208(G). The change removes the language that Business Entities are not required to complete continuing education. That language is important. I disagree with the reduction in continuing education hours. In the many board meetings which I’ve attended, division staff and the board seem to feel that LDPs are barely competent. Why then would the number of continuing education hours be reduced? Yes, I’ve heard the argument that LDPs are not doing their education hours currently. That is not acceptable. LDPs must rise to a level of professionalism and complete their continuing education. I agree that the continuing education time frame should be every certification period, but I think the hours required should be twenty (20) per 2-year period.

7-208(L). I disagree with the requirement of 3(b). I do not believe that division staff needs to be tasked with providing a 2-hour long class that takes away from substantive continuing education. I think if division staff (who already have plenty to do) want to prepare a class, they should provide an outline of what will be taught to determine if this is actually relevant to the profession. Then, we as LDPs could perhaps have some input. As it stands, this class on the “role and responsibilities” is covered by our professional association, Arizona Association of Independent Paralegals, as part of ethics training at each seminar.

I disagree with the increase in ethics hours. If the continuing education period is two years, then ethics should be two hours. Again, I think the priority for continuing education should be in substantive areas.

I disagree with the change to credit hours from tax related curriculum. Taxes are an integral part of understanding how to avoid estate and income tax implications when preparing a trust. For those who prepare trusts, they need to stay competent in the tax law related to trusts.
--
Prior to seeing these proposed changes, I was working on a proposed change to 7-208 which I had not yet submitted to the Administrative Director. I will upload that proposed change because I believe that is the change that we actually need to increase access to justice and update the continuing education requirements.

ALLEN D. MERRILL (80098) COMMENT ON:

PROPOSED AMENDMENTS TO ACJA SECTION 7-208 (“Code”)
DATED: AUGUST 2, 2021

After reading the proposed Amendments to the Code, I see that some of them are basically “housekeeping” amendments, but at least one of the amendments seems to be in direct contradiction of the intent of the Code, which is to provide more access to legal services for the people of Arizona. After 18 years of the certification program, and the serving of hundreds of thousands of customers by CLDPs, it appears that the author, presumably the CLDP Staff Attorney, is now attempting to restrict many of those services and doing so without any documentation whatsoever of the reasons for this attempt. Thus, some of these amendments are actually an attempt to REDUCE access to legal services.
If these amendments succeed, the citizens of Arizona will not be happy. If these restrictions on the access to justice are implemented, barring legal actions to prevent them, and the public hears about the court’s decision to limit the consumer’s access to justice, there will be a lot of disserviced and angry Arizonans.

My objections are as follows:

PROPOSED ADDITION TO SECTION F 1. a. Authorized Services
A legal document preparer shall not draft substantive legal motions, supporting memorandum or appellate briefs, except that a legal document preparer may assist a client with completion of motions in family court proceedings using the appropriate court approved motions form;

COMMENT:
This is the codification of the personal opinion previously expressed by the Staff Attorney in prior disciplinary actions wherein actions by the Staff do discipline CLDPs for preparing “substantive motions” and doing “legal research” failed because, in fact, there was no restriction to that effect in the Code and the design of the Code was in fact, to allow full preparation of “any document for which the LDP is competent to prepare”. Now, in this amendment, such “codification” appears to be more an effort to enhance bureaucratic power and lawyer income at the expense of thousands of Arizona citizens. The Staff Attorney has not shown any complaints or damages alleged by consumers because LDPs have created substantive motions and it is doubtful that any were. All complaints of this kind, which are incredibly few, as far as I know, were filed by attorneys or the Staff. The author of this addition should be required to provide written documentation of a significant number of consumer complaints or alleged damages for this addition.
The term “substantive motion” is intentionally vague, leaving the interpretation open to the Staff Attorney and/or the Board, presumably at the time of any disciplinary hearings, a circumstance that is designed to limit the LDP to a mere scrivener and a condition that the Code purposefully was designed to avoid. The author of this addition should be required to give examples and make specific delineations of the term “substantive motion”. Even then, this restriction will be extremely detrimental to the access to justice by Arizonans.
This issue was brought up at meetings of the two year-long task force entitled “2020 Arizona Access to Justice Commission” at which time several members of that task force, including some Superior Court Judges, questioned how an LDP could provide their services competently without legal research and so-called substantive motions. Even one of the Task Force members, an appeals court judge, and himself an opponent of the LDP program, commented that, “if you are going to give these people this ability [ to prepare legal documents for Pro Se filers] it is wrong to deny them the tools to do the best job they can”. This amendment most assuredly will deny those tools.
The purported purpose of the Access To Justice task force was to enhance the public’s “access to legal services”. In fact, this addition to 7-208 does exactly the opposite. It restricts the LDP’s ability to provided competent services to those Arizonans who cannot afford the services of a lawyer, leaving them to handle the matter by themselves or lose their case by default.
The “bone” thrown to CLDP’s in this addition to the Code, that of being able to draft substantive motions using “court approved” forms for Family Law matters only, is ridiculous on its face. To begin with, the Rules of Civil Procedure, while providing basic requirements for preparation of motions, orders, etc., does not actually “approve” any substantive motion forms. The Self-Service Center forms, while helpful, are not truly “approved” forms. And…while the Family Rules do have a few such forms, the numbers of those forms are so limited as to be pointless. Finally, to limit the preparation of those forms to Family law essentially leaves the small businesses, individual civil, individual tax issues, immigration and individual probate matters “out in the cold” . To me, it indicates that the author of these amendments is more interested in enhancing a personal agenda than that of “providing access to legal services”.
I have heard recently that these proposed amendments to 7-208, particularly those that restrict the previously allowed functions of LDPs, can “be handled by the new tier “Nonlawyer Legal Service Providers” (“NLSP”). Even if that is true, it will be years before the numbers of NLSPs, and the expansion of work that they are allowed to do, will fill in the need that consumers have for certain legal assistance. In the meantime, you are leaving the public without the competent help that they can afford to take care of legal issues and is currently available.
All in all, this addition to 7-208 is unsupported by evidence or documentation, is detrimental to providing “access to justice” and leaves LDP’s who are honestly trying to provide competent services to Arizona consumers, open to unnecessary, unsupported and biased attacks by the Staff who will be able to created a definition on their own for such attacks. If enacted, it will truly deny “access to justice” for thousands of Arizonans. This addition should be eliminated from the amendments to 7-208 in its entirety.

PROPOSED ADDITION TO SECTION L. 3. b. Responsibilities of Legal Document Preparers:
Upon receipt of notice of board approval of individual certification and before April 30th of the following odd numbered year, each legal document preparer shall attend and complete a two hour professionalism training course on the role and responsibilities of the certified legal document preparer as provided by the division staff.

COMMENT:
This addition to the Code is again a codification of what incorrectly was attempted in years past by the Staff in which they attempted to inculcated their own personal opinions into a similar “class”. So… the question is: If the Code adequately presents the role and responsibilities of the LDP, what is the point of this class? Is it to, again, inculcate, the opinions and agendas of the Staff or the Staff Attorney? Further, the absence of any actual plan for the class presents a question as to whether any of the teachers, presumably staff members who have never been a CLDP, have the knowledge or experience to teach it.
For CLDPs who have practiced for many years without undue violations of the Code, this is not only an insult to them, but a waste of time and money for the Court. Is this class one of the reasons the fees have gone up?
Again, this addition is intentionally vague, with no explanation of how said Class will be presented and specifically what will be taught. Prior to any review or approval of this amendment by the Court or Administration, the author should be required to provide that information in specific and not vague or general form and to explain how the staff will be competent to teach the class to experienced CLDPs.
This additions should be removed and the “Class” eliminated. It is another one of those bureaucratic boondoggles that professional boards are prone to dream up.

PROPOSED DELETION TO SECTION E.3.b.(6)(a)(iv) and E.3.b.(6)(b)(iv) Individual Standard Certification:
Removal of “as a court employee” for law-related experience.

COMMENT: As with all previously mentioned amendments to the Code, this amendment does not show any justification or reasoning for it. The current Code requires that even court employees must have “law-related” experience so what is the point in eliminating that “experience” as qualifying under the Code? I understand that there have been many former court employees that have served successfully as CLDPs, so it seems untoward to be removing that “experience” as qualifying now.

Allen D. Merrill, AZ CLDP No. 80098

August 13, 2021

Certified Legal Document Preparers Program Attn: Mark D. Wilson
Certification and Licensing Division

Re: July 21, 2021 Proposed Changes to ACJA § 7-208

Here we are, back again, to address some proposed rule changes and code language that sounds eerily the same as the suggestions that were made that ended up with a TASK FORCE being commissioned to review the rules and responsibilities of CLDPs. If I recall, that Task Force did not change any of the language that allows us to prepare the paperwork necessary to assist the general public who are unrepresented. They DID find that adding another level of licensing for those who want to further their services and “practices” to assist those in the general public was probably a good idea, so they did. It was not found that we as CLDPs were incompetent or causing harm to the general public, that the complaint rate from the general public was relatively low. It was found that CLDPs were beneficial to the system and to the unrepresented public. What was in the statistics was that it was moreso attorneys that were filing complaints against us. I, personally, have had attorneys file complaints against me…and in my opinion, mostly frivolously (ego-driven). But I will get to more of that later.

I whole-heartedly agree with Arlene Rheinfelder in most all of her response, as this is the heart of the matter.
QUOTE:
“When establishing the legal document preparer program, the purpose was clearly stated: “… the need to protect the public from possible harm caused by nonlawyers providing legal services must be balanced against the public’s need for access to legal services.” ACJA 7-208(C) emphasis added. The program was established to “Protect the public through the certification of legal document preparers to ensure conformance to the highest ethical standards and performance of responsibilities in a professional and competent manner.” ACJA 7-208(C)(1)”
QUOTE:
“After a two-year task force on increasing access to legal services and introducing the LP program, which has yet to have any certificates issued and will only include practitioners in family law at the beginning, we see a proposed change to ACJA 7-208 that will reduce access to legal services. This is at a time when the recently released 2020 Arizona Access to Justice Commission Annual Report states:
"Legal aid agencies remain overwhelmed with demand for civil legal assistance. These agencies face actual or potential loss of funding, threatening not only the timely delivery of legal services but also the capacity to administer an effective volunteer lawyer program. Quick access to useful legal information that can be understood and used by self- represented litigants (“SRLs”) remains a critical need." (p. 3) (March 2021)”

I could not have worded this more clearly or effectively. What I do not understand is why do we go through the trouble to obtain the schooling and/or experience required, pay fees to get certified, have to pass a lengthy test to prove our competence, and then be required to keep our knowledge base updated with continuing education, if the board that oversees us, and the attorney who is supposed to be defending us, CONTINUES to want to tie our hands and strip us of the exact things that are needed to help the general public?? Prior to the task force being commissioned, it was similar proposed language, stripping us of being able to prepare documents and turning us into glorified space filler-inners. This new proposal, to me, is just a back-door approach to achieving the same thing – start with small things to prohibit and work our way through prohibiting each document over time. Seriously? Who else is seeing this??

How in the world am I supposed to assist a person trying to get through a divorce with children when there is a particularly sticky custody arrangement going on and someone wants their child to talk to the Judge? Am I not going to be allowed to include a Motion for In-Camera Interview of Minor Child Pursuant to Rule 12? Is that a “substantive” legal motion? And WHO is going to determine what “substantive” means any “legal motions, supporting memorandum or appellate briefs”? Or is the true intent of that (should’ve just said) to prohibit all legal motions, supporting memorandum or appellate briefs? I have several attorneys (and a couple of judges) who send people to me to assist with low-income cases to get through these matters. If you would like their names, I will send them to you privately. And I will go so far as to say that one of those attorneys has told me personally that I make him work for his money if my paperwork comes across his desk. So is that the issue? Does it irk attorneys that someone not of their assumed caliber would be smart enough to make them have to put in a little effort for their case to earn their money?
We live in the lowest-income area of the state. Attorneys here are overwhelmed and so is our Legal Aid offices. And our population is growing thanks to the chaos happening all over our country. I used to work for a very smart lady who once said “there’s enough business for everybody.”

Allow me to circle back to complaints filed against me by attorneys to make this point. I was hired (begged by) someone who did not have the money for an attorney to assist him with a responding appellate brief. The Appellate Court did not reject the document. However, they kicked it back at him because I failed to make enough copies and/or put the correct color sheet on top of them. They asked it be corrected and re-submitted. The attorney for the opposing party immediately filed a complaint against me alleging that I did not have the competence to create the responding brief because I did not make enough copies or put the correct color on the covers. Seriously? Does that sound like a knee-jerk complaint or one due to incompetence? Or was she just irritated because it was a pretty good responding brief? Or how about the phone call I received from a very old local attorney who threatened to take everything I own if I DARED to prepare and send another 20-day preliminary notice to the water company he represented? “Do I make myself clear!?!”

Let me reiterate what I said at the Task Force meeting I was invited to by the commission: By regulation, Notary Publics are allowed to assist people with filling in the blanks on documents.

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So my question is: What is really the motive for tying our hands and crippling us in our services of helping the general public?
WE ARE CERTIFIED. We are doing what we do, under your requirements, because we WANT TO HELP those who cannot navigate the system or do not have the means to obtain an attorney. We become more competent over the years in dealing with varying situations for our customers and in our required continuing education, which, by the way, I end up doing much of mine through the State Bar of Arizona online due to the excessive expenses regarding travel because of my location. I am obtaining the same continuing education that is offered to attorneys. And I go to CLE presented by attorneys if I deem it valuable for documents I prepare. If you strip us of the means to help the general public, why would we need to get certified??? I could just be a Notary Public and help people fill in the blanks! Then, the Supreme Court has no jurisdiction over me if I harm the general public. And since there is no longer the UNAUTHORIZED PRACTICE OF LAW statute on the books, I will repeat what a Court Administrative professional/pro tem Justice (who used to be a CLDP) said upon learning that, “Then why would ANYBODY need to get/be certified?”

Now on to the proposed change of language regarding legal research. I can only for speak for myself, but I believe it applies to all of us if we are doing our jobs right, that I spend a lot of my time trying to guide/teach/educate people on what they are doing in trying to represent themselves. I have made it my routine to help people to find statutes and other items that they may need to help themselves. Regarding the proposed language, to try to differentiate between doing legal research for general legal principles, then in the next breath (sentence) say “shall not perform legal research for the purpose of providing a legal opinion, advice, or advocating a legal theory” is dangerous to CLDPs. This language has the ability to be manipulated in any situation to accuse someone of doing something they may have honestly not been doing. It is more legal loophole language that could potentially be used by anyone to form a false narrative, in my opinion. I, personally, have made it my routine to NOT lead people in one direction or another, to just get through their paperwork and legal procedures. They usually have a general idea of what's wrong/right or what they are needing.

And now for the fun one! ACJA 7-208 L(3)(b)
When an attorney has passed the bar, and then before opening a private practice, is he/she required to attend “a two-hour professionalism training course on the role and responsibilities of an attorney?” Inquiring minds really want to know, because I’ve met some that could really use that, and more!!
Is this a one-time requirement upon initial certification? Or is this going to be mandated upon each renewal cycle as well? Either way, see previous inquiry!

Re: L(9)(b)
HUH?!? What does ANY of that say???

I understand that the courts are attempting to make access to legal procedures more available online, and in the attempts to do so, are doing a couple of things as I see them: 1) It’s assuming that people first have the time to do this themselves; 2) It’s assuming the people can understand and get through 3-5 hours worth of questions and instructions of how to get through procedures; 3) It’s assuming ALL people have the comprehension and capacity, and are going to use it. The majority of people that I assist in my office are people who are either overwhelmed by the whole process and do NOT understand the language, or have no comprehension to the system, or people who quite simply do not have the time due to work, family, and/or all the other obligations and responsibilities going on in their lives. Respectfully, attorneys/the Board have no idea how often I hear “I just don’t understand all this and I’m afraid I won’t fill out the paperwork right.” There have been many times that I have had someone come in with “do-it-yourself” documents that were finalized with the court that ended up completely screwing one or the other party, and they are asking me to help take it back to court.

In the attempts to tie our hands, it eliminates the option people have to use the option of a CLDP effectively, which will in turn give less options to the legal system in our state, and we reach a group of people that other options do not reach. With our program, people at least have another affordable option available to them that they have recourse if we do something that harms them. And in the information I have been able to obtain regarding the history of the program, that percentage has been quite low. What I do believe is that in the world of attorneys, courts, and legal systems that are in major cities and highly populated areas with many options, do NOT understand that to provide assistance to those who live in a area/county that is not directly visible to them with the highest poverty levels, do not understand the value of our program. We are a second-home community, mostly, that has only one option for people who serve that type of population, and they have to be seriously indigent in order to receive help from White Mountain Legal Aid. And they are so seriously overwhelmed and restricted to the types of cases they can accept due to being overwhelmed. They, too, refer people to my office in certain cases. I receive people sent by judges, attorneys, title companies, Legal Aid, and general public.

I recall during one of the Task Force commission meetings that several of us were invited to for our input, comments being made by two individuals specifically, a judge and an attorney. The judge was banging his head on his phone muttering that “they’re practicing law”. The other person, attorney, responded to him saying “that’s why they’re here under the AZ Supreme Court. The AZ Supreme Court has jurisdiction over the practice of law.”

If having to come back every two to three (2-3) years to defend the original intent of the program is necessary because some attorney(s) feel (subjective opinion) that we “should” not be preparing documents for whatever their subjective reasons are, then the wrong attorney(s) is/are on the board to represent us. Allow me to clarify my meaning of that statement. I have been contracted by an attorney licensed in California several times to assist with paperwork and processes for properties that he owns in Arizona. I explained to him some time ago that the attacks being made to us as CLDPs are by no less than the attorney on the staff that oversees our program, and his comment was roughly this, “Why is the attorney that is supposed to be defending and helping you coming after you and making things more difficult?” And another comment regarding attorneys filing complaints against a CLDP was “If an attorney feels the need to attack someone in your position, then he’s probably not a very good attorney.”

I really think that any attorney on our staff needs to NOT be a fox overlooking our henhouse. Language to clarify the Judicial Code would be much more helpful than language to strip of the tools we need to assist others.
Respectfully,
S.L. Caley, AZ CLDP #81026

P.S.
A few points I passed over in my original response:
1. In the attempts of whomever it may be that is attempting to remove our ability to draft certain documents, you then will embolden the Randi Rosen(s) of the world (Please feel free to look up those cases in Maricopa County and Navajo County), not to mention the numerous many others that are providing legal services under the table for a fee, which include (to my knowledge) "paralegals" registered with local county courts (feeling free to provide document services to the general public under the auspices of registration with courts), filing counter clerks (had a customer inform me that I charged more than the clerk did who prepared her divorce paperwork on the side), and paralegals in general with a blatant disregard to Arizona Judicial Code and statutory regulations (which, again I will point out now there is no statute for the "Unauthorized Practice of Law").

2. I will reiterate, CLDPs are operating under the rules and in a manner which holds those certificate holders accountable if they do anything to harm the public. If the attempt to tie our hands in our work is to possibly benefit the newly created LLLP program succeed, while at the same time diminishing the need for CLDPs, and/or "lowering" its usefulness, which, I believe it will do just that. And I am sure that there is more than just myself who may not be interested in "representing" those who come to us for document assistance. Just as I know attorneys that do not want to be litigators, there are probably CLDPs that only want to prepare documents and assist with procedures. But if you start taking away documents that we can prepare, you only succeed in making us ineffective as CLDPs. Which now makes me wonder if it's a micromanagement issue of why such changes are being proposed. Is that the end game? To eliminate the CLDP?
Let me add that I know when I get to a point that I MUST tell someone to get an attorney (as well as the dictated response according to Code), that they clearly need someone more knowledgeable and practicing law. One of my regular admonishments to my office receptionist is "DO NOT GUESS" when they are speaking with someone. If you do not know the answer to a question, tell them you "do not know, and will get back to them with an answer," even if that answer is "We're sorry, we do not give legal advice, and you need to call an attorney."

3. Lastly, the lowest rate attorney's office in our area is $200.00 per hour and he has a full staff. And they are popular in our area due to sheer volume of business and his reputation for being in business a long time (good, bad, or indifferent). In practical terms, looking at your LLLP program, it does not make sense for me to change or add certifications at this juncture as I am not interested in personally representing someone, maintaining trust accounts, paying dues and answering to the bar as well as the board, and maintaining the level of insurance needed if I was to practice law on a limited basis. And to try to find ANYBODY in our area with half a brain and the desire to work or learn is a whole other topic! It is all an increase in overhead. And with all those additional requirements, it will force rates to go up to cover those costs and maintain any profit. And who, in one of the poorest counties in the state, is going to pay a LLLP $150 (?) per hour when we have attorneys charging $200 per hour?

The proposed regulation of what documents I can/cannot prepare makes no sense to someone [me] that has been assisting (legally) people with document and procedure assistance for as many years as I have, unless the final result is to eliminate us as a whole one piece/document at a time. Is that the motive? It seems as though it is in my mind's eye...sadly.