Re: December 8, 2021-Proposed Changes to ACJA § 7-208
Second Posting
In Response:

Here we go again. Attempts to change rule language that will inevitably put a CERTIFIED Legal Document Preparer in the cross-hairs of many aggrieved attorneys and/or put us out of business. The proposed rule changes and code language still 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. AGAIN,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, Self-Represented Litigant (“SRL”), however, it is under attack once more.

First, I agree with all other responses and points of view provided in this forum to date, AND I refer to ALL of the initial responses provided when this issue first arose, AGAIN, in July of 2021, and incorporate them as inclusive in this, my current response. In reading other current responding statements, I agree with them and can determine that they all are grounded in day-to-day experience and use in what we do for the SRL.

Please allow me to provide another example of HOW the rule language of “Legal Outcome-Based Research” WILL stop me from effectively assisting others in our area who actively use my services to assist them.
Among other documents prepared by this office in other areas of law, I prepare innumerous amounts of real property deeds and documents to effectively CHANGE title and vesting from one person to another. I assist many SRL’s that are guided to my office by local title companies, local attorneys, judges, and Navajo County official government offices for these purposes. Under the new rule language change, the rules will fully stop me from being an effective document preparer for documents that I currently provide.
Currently, when a SRL comes in to request a deed change (changing someone’s rights to property), I generally ask them if they have a copy or original deed for whatever property they are working with for reference and vesting, or a title company has informed them that something specific needs to be done and they provide a title report. Our office is a referred place to call/go to for many of those services. Most of the time the response regarding a deed is that they do not have one (many long-term property owners). I then ask them if they will allow me to look up their property to find current vesting. I usually do get permission (AND, thankfully, it is public record). Upon RESEARCHING the vesting on property, about 35% of the time, there is something else that is different than what the SRL was expecting to do.

My question now becomes, what is “LEGAL OUTCOME-BASED RESEARCH?” Is this not “Legal Outcome-Based Research” as defined? And if I do not do an allowed search (double-check) on property prior to preparing a document as requested, am I not doing a disservice to the person(s) who has come to me for assistance regarding the changes to their title/vesting? If I blindly agree to preparing a document as that person has requested WITHOUT making sure that I am not creating a huge legal problem with their property, am I not causing harm to others? You all have no idea the problems I have helped fix from other CLDP’s who HAVE NOT DONE any research by doing “Legal Outcome-Based Research.”
To me, if you incorporate this language, “Legal document preparers may not perform legal research for the purpose of providing specific advice, opinions, or recommendations about possible legal rights, remedies, defenses, options or strategies” the staff has effectively made me INEFFECTIVE as a resource for our community, our title companies, and our official County government offices that I work with directly in correcting so many problems with our rural parcels and real property issues. If our office is not allowed to do “LEGAL OUTCOME-BASED RESEARCH,” even at the permission of the land-owner, my hands have become tied to correctly providing our services. Real property documents and civil procedures have become around 50% of my business requests. This percentage does not include the services provided toward estate planning and property vesting for those purposes. Legal Outcome-Based Research is necessary for those real property transfer documents as well.

This language not only STOPS us from doing simple motions, but also stops everything we do to make sure that we are not causing harm to the general public. ALL RESEARCH can be interpreted as “Legal Outcome-Based Research.” What research is not, or does not have, legal outcome? Research is done to assist in making a decision about everything, and to make sure that the proper statute still applies to whatever basic pleading is being used (after statutory changes to our laws), and/or the proper rule is being followed according to the Arizona Rules of Court in ALL legal procedures (because they change too or I would not receive a new book every year).
The term “Legal Outcome-Based Research” is very broad term and can be interpreted in any way that any attorney wants in order to make complaint against a CLDP. And I will go so far as to state again that my perception from being AT the Task Force meeting and these rule change requests are being designed to stop us from LEGALLY assisting the unrepresented general public in their legal matters when they cannot afford to pay attorneys. And that is a HUGE DISSERVICE to the public. There is really little to no evidence that we are harming others in our current capacities.

In comprehending the newly worded legal term addition and definition, it appears that whomever is attempting these changes is assuming that CLDP’s are focused on family law documents/procedures, and/or civil law documents/procedures, and that this is necessary to stop a CLDP from creating a legal argument that must be defended by either another SRL or an attorney. And it seems that the biggest concern is that creating a document with a stance/legal argument/remedy is what is determined as “the practice of law,” which is what the change is trying to regulate. I do not have any suggestions regarding that being accomplished, however, I do believe that it is only necessary to those on the Board or involved in our program who seem to want only an attorney or a SRL to be qualified to do that. My biggest concern as a practicing CLDP is how this language has the probability of causing harm when there is none due.
 
We are engaged in a profession that we exercise a limited level of the practice of law. How much the Board or Supreme Court wants to restrict us from what we are doing seems to be where the issue lies. If we are restricted greatly (the first submission of language) than it is a huge disservice in continuing the LDP program and puts most of us out of business. If we are restricted minimally, or greater, in order to make some attorneys/judges more comfortable, is it only satisfying those in the industry? Or is it actually doing service to the 85%-90% of unrepresented public in Arizona that needs access to people in our program? Where to draw the line is the issue. My question is then, how much has this come up in the complaint department? Are the complaints generally from attorneys? If they are, why is that not put into perspective? Why is the goal to limit, even more, our level of limited practice of law versus limiting attorneys from filing complaints against CLDPs?
In my years of doing this limited level of the practice of law, I made a choice after I got into this (after hearing from other CLDPs) that I was not going to include any case research in legal pleadings unless a client walked in with that case research in their hands and asked for it to be included. I made that decision for a couple of reasons: 1) To me, it was a clear practice of law to research cases and use case law in an argument that a regular John Doe/Jane Doe would not do; AND 2) I did not want to be accused of and charged with the unauthorized practice of law (still on the A.R.S. books when I started this) as a result of practicing case law, because back then, most attorneys and anyone else in the system made their attitudes clear that they did not accept a CLDP as a valid person/position in the legal system (at least not up here in this rural area). It ended up affording me a much less volatile environment and personal defenses. It actually paid off. Sticking to statutes and the rules of court helped the perception of what I did to NOT BE that of an attorney, and more closely replicating that of a Self-Represented Litigant. THAT is what we do/do not do – we do NOT give advice as to what anyone should or should not do (assimilated from an old CLE on the AZ Bar website-“If it is an answer to a question that could be posed as “Should I do this? Or this?”) and provide legal documents and assistance regarding legal procedure.
Legal document preparation is a practice of law that “effects the rights of an individual.” EVERYTHING that we do requires some level of research and has the possible impact of changing someone’s life. Keeping that in mind when I do what it is that I do as a CLDP has been paramount to all else that gets done in my office because it better be right or I have caused harm! And it cannot be right if I do not do “LEGAL OUTCOME-BASED RESEARCH!”

I will again include Arlene’s Rheinfelder’s quote from the first round in my response:
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)”

Let us move on to some of the even more specific changes:

ACJA 7-208 F(1)(a)
1. Authorized Services. A certified legal document preparer is authorized to:
“a. Prepare or provide legal documents, without the supervision of an attorney, for a person or entity in “a” legal matter when that person or entity is not represented by an attorney. A legal document preparer shall not draft “documents that require legal outcome-based research, except that a legal document preparer may assist a client with the completion of motions in family court proceedings using the appropriate court approved motions form:”

If I read this correctly, again, it applies strict limits to the documents a CLDP is allowed to do and how they must be done. I, personally, DO NOT USE court supplied template documents. If a document is a hand-written document by a client, my name/CLDP number WILL NOT BE PLACED ON THAT DOCUMENT. All of my documents have been type-written and are computer-generated documents that are locked/secured if transferred by email or printed and signed in front of a Notary Public in order to avoid client manipulation and to avoid any claim from a client that may decide to be vindictive due to loss of a case, changing/placing language that was not used by me, the CLDP. It is a huge liability.
Again I ask, what is the motive for adding this language? Is it solely to restrict the CLDP from creating a “legal argument” that in turn is to be litigated in a legal procedure? I have personally referred people to attorneys when the case has boiled into a problematic litigation, when drafting a full-on legal argument with case law and statutes must be utilized for a judge to make a ruling. I leave the decision to the client with the advice of their attorney.

“d. Conduct legal research necessary to understand general legal principles to assist a client identify and complete a competent legal form or document. A legal document preparer shall not perform legal outcome-based research as defined in this code.”

See all of the above in rebuttal to this paragraph.

ACJA 7-208 K(5)(f)
f. Delinquent Continuing Education $250.00

Is this not a little extreme??? With EVERYTHING going up in price at an extremely fast pace, can we not push this to this level at this time? I get that you want it to hurt, but seriously? Can this be reconsidered at the $100-$150 level?

Any other changes not specifically addressed here generally means that I am not opposed to said proposed changes.

 
I will reiterate from the first proposed change:
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??
WE ARE CERTIFIED. We are doing what we do, under SUPREME COURT REGULATIONS, because we WANT TO HELP those who cannot navigate the system or do not have the means to obtain an attorney AND do it legally.

If you strip us of the tools and 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 would have no jurisdiction over me if I harm the general public. And since THERE IS NO LONGER an 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?”

PLEASE consider, 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 and 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, legal systems, that are in major cities and highly populated areas with many options, do NOT understand that to provide assistance to those in a 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, which they are 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 the general public.


Respectfully, S.L. Caley, AZ CLDP #81026

In response to the “Second Posting” of the proposed ACJA § 7-208 rule change, I comment as follows:

I reaffirm my initial objection to these proposed rule changes because they continue to offer a resolution to a problem that does NOT actually exist. Neither the Board of Nonlawyer Legal Service Providers or division staff have provided any justification as to why such drastic changes to the rules regulating Legal Document Preparers (“LDP”) are warranted.

One would assume that such changes are in response to a multitude of complaints filed by the public concerning substandard work product being produced by LDPs. However, my firsthand observation of multiple board meetings over the last 3 years would strongly contradict that assumption. The number of public complaints that I have seen the Board address over the years has been minimal and of those even less were considered actionable. Most often it seems that the complaints are made by attorneys or judges who allege that an LDP committed an unauthorized practice of law and had nothing to do with actual harm caused consumer.

If these proposed changes are in response to the recommendations of the Task Force on the Delivery of Legal Services, then I believe they are in direct conflict with the task force’s stated mission to increase the public’s access to legal services.

My first specific objection to this draft is the addition of the “legal outcome-based research” definition as outlined in Section A because it’s far too restrictive. How do you expect an LDP to prepare a competent legal document for a consumer when the LDP is restricted from doing the necessary research to ensure that the document is prepared correctly? How does this serve the public who is paying for such service?

Also, if these proposed changes are in response to the recommendations of the task force, then I ask the Court and/or Board to seriously consider Hon. Peter B. Swann’s opinion as it relates to legal research and advice, which states as follows:

“Any person is free to conduct legal research, and I cannot see how the Court can lawfully prohibit such research. But even if a prohibition were constitutionally possible, where is the public good in such a proposal? The Court has already created the LDP tier of practitioners, and any notion that they do not provide legal advice is folly. Legal advice is inherent in any aspect of the practice of law, and a LDP cannot properly fill out a form or prepare an original document without creating legal consequences.
It is essential, if we are to have such a tier in Arizona, that LDPs be empowered to provide the best service possible to clients. An uninformed LDP is an ineffective or even dangerous LDP, and I submit that LDPs should face no restrictions on research activities. If we cannot trust LDPs to conduct legal research, then we should not allow them to practice law in any form. But I have no reason to believe that LDPs would not be able to conduct legal research appropriately as long as the services they offer do not exceed the scope authorized by the code. I would therefore delete the restriction…”

Although Judge Swann appears to not be in favor of the LDP program, he is absolutely right about this, and he does an excellent job of outlining the ridiculousness of restricting an LDP’s ability to perform research.

My second specific objection to this draft is the change of “any legal matter” to “a legal matter” in Section F under Authorized Services, paragraph a. The section goes on to restrict the LDP from preparing documents that require legal outcome-based research which is counterproductive and completely unnecessary.
The existing rules already outline two crucial restrictions:

1) A legal document preparer shall accept only those assignments for which the legal document preparer’s level of competence will result in the preparation of an accurate document; and

2) A legal document preparer shall not provide any kind of advice, opinion, or recommendation to a consumer about possible legal rights, remedies, defenses, options, or strategies.

Why aren’t those regulations enough? They are clear and straight forward, and if an LDP is working beyond their individual skill level or offering more than legal information to a client, then the Board should address the problem specifically with the offending LDP as they do now.

The whole goal of LDP program is to increase the public’s access to justice while also protecting them from incompetent practitioners. The proposed rule changes to ACJA § 7-208 do the exact opposite and essentially gut a highly successful program which provides the public with a beneficial legal resource that it wouldn’t otherwise have access to. We should be looking for ways to expand the LDP program so that more people may be helped instead of seeking to further restrict it.

Do not punish the people of Arizona who rely on LDPs as a vital resource. The people who will be most harmed by these rule changes are those who cannot afford an attorney, but also do not qualify for free legal aid even if they live in an area where such resources are available.

If the Court and/or Board of Nonlawyer Legal Service Providers are interested in improving the Certified Legal Document Program, then I suggest creating a task force or committee that is specifically charged with improving the program but LDPs should be included as members of the committee so that they may be part of the conversation.

Regardless of future opportunities to meet the legal needs of the public, these proposed rule changes are not the answer and should be rejected outright.

Respectfully,

Melissa Hill, AZCLDP 81696

I am not a stupid person. I’m a college graduate, have worked in the legal profession for nearly 40 years, and have owned and operated my LDP firm, Divorce Packet Processing, for almost 35. I was also appointed by the Arizona Supreme Court to help draft the rules that now govern LDP’s. But I’m not clear as to what this proposed code change says. Or, more so, is trying to accomplish. Or why.

It seems this change simply repeats what our code already says: that an LDP “may not provide any kind of specific advice, opinion, or recommendation to a person or entity about possible legal rights, remedies, defenses, options or strategies”. So it seems the proposed code change, by literally reiterating what’s already in the code, is simply noting that this applies to legal outcome-based research. But what research in the legal profession is not legal-outcome based?

And an LDP must do research, including what the current laws are (those on the books and thus factual in nature), case law (what’s not on the books yet so more general) and procedures (which often are nowhere to be found anywhere in writing but the courts just do. And then change. And change again). Even attending a CLE is doing research. Which is something we have to do. So to do our job properly, we must do research. And, again, what research in the legal profession is NOT legal outcome-based?

So is this change saying that research cannot be with the intent of supporting a specific outcome? As the proposal states “prohibits applying that research to the facts of a client’s case to advocate for an outcome”. But not only MUST we stick to the facts, but why else would anyone have a case other than to advocate for an outcome?

Is this change saying you shouldn’t show research that only supports one side? Well, that’s basically saying don’t do a poor job of researching. And seems doing a poor job is already addressed in the code.

Is this change saying you can’t do research specific for a specific client? Well, that would be wrong. As that wouldn’t allow us to do our job properly. We may start out in this profession knowing enough to become certified, but the truth is few know everything. So when a client comes to us about an issue we’re not familiar with, we must research it. And even for those who do know everything (or think they do), things change. So we must conduct research to keep current with the law. And often, while we know there may have been changes in a certain area, we don’t spend the time to research it until a client comes in with a situation in that area. So, again, to do our job properly, we then must research it.

An example of this is that while the child support guidelines recently changed as to how spousal maintenance is considered, I’ve yet to research how it’s changed. But eventually, when a client comes to me who wants to pay spousal maintenance, I’ll have to do so. And I’ll be “applying that research to the facts of a client’s case to advocate for an outcome”. But I must do that to do my job properly.

Does this change mean we can’t be the first to learn something? And we have to wait for it to become rule or common knowledge? As we can’t. As LDPs, we file motions on a regular basis to help our clients get their words to a judge. And especially in family law, with things regularly changing and/or people with unique situations, we have to research the latest information and then present it to the court. And often we’re first to do so, even before attorneys, because we run into these things more often. Simply because we deal with more people than they do.

Several years ago I had a client who was having trouble getting her husband served. And rather than saying, sorry, nothing I can do, I did some research. I called several attorneys, spoke to people in other counties, and I found that some judges had allowed service through email and even social media. After I let my client know, we prepared a motion asking she be allowed to serve through Facebook Messenger. And the motion was granted. This was years ago and while not on the books yet, it’s now allowed on a regular basis. So it’s now general legal information. But back when I researched it (or for those not aware of this option and now research it), it’s applying research to the facts of a client’s case to advocate for an outcome. Which would be prohibited under the proposed change.

I also had a client who had a judge refuse a postal receipt as proof of service because it was signed by someone besides the other party. This was in the early days of the pandemic and after researching the matter, I found that postal carriers were no longer allowed to hand a person the receipt to sign. And instead signed for the person with their own name. Which is why the judge had refused the postal receipt. After presenting this research to my client, we filed a motion with the judge to allow the mail carrier’s signature. In addition, I copied it to the presiding judge. And not only was the motion granted, but my research is posted almost verbatim on the court website. So it’s now general legal information. Did I conduct legal outcome-based research and then apply it to the facts of a client’s case to advocate for an outcome? Yes. Which would violate the proposed change. But was I providing “specific legal advice, opinion or recommendation”? No, because the research I found was applicable to others. Thus, falling under the category of “general legal information”.

Granted, it is a fine line as to what is information and what is advice. We recognized this when we wrote the code. The committee (consisting of both attorneys and non-attorneys) reviewed numerous scenarios. And all were in agreement which ones crossed that line. And thus agreed where that line was. But when it came to defining it in the code, it was difficult to put into words. And that’s why we wrote the code as it is, ie: allowing the providing of both general legal information and factual information but not specific advice, opinion or recommendation. And we provided for a board that would consist of both attorneys and LDPs. As we trusted that, just like we knew where that line was, so would they.
And it seems to be working. As there doesn’t seem to be a high volume of complaints about people crossing that line. So not sure why this change is even being proposed. Is there a high volume of LDPs conducting research that crosses the line? I don’t think so. Is there a reason to try to attempt to further define the above line? I don’t think so. And even if there were, this proposed change is a very poor attempt to do so. As, again, I’m not stupid, and I don’t understand it.

In summary, the proposed change is both unnecessary and unclear. With its room for wide interpretation, it could easily put our profession and, more so, the community at large at risk. The services LDPs presently provide (all with little or no problems) are much needed. Were this proposed change allowed, we would no longer be able to serve the public as we presently do. Which would cause far, far, far more harm than any alleged issues those proposing this change may have concerns about.

Have also attached my response as a word document, as may be easier to read.
Sincerely,
Linda Seger
AZCLDP #80290

Response to “Second Posting”
ACJA § 7-208 rule change

The purpose of this very successful program was created from the fact that many people in our state are deprived of the legal system simply because they are unable to afford an attorney to prepare documents that include legal research. They are deprived of justice because of a lack of money or the ability to write documents based on legal research to be heard in our justice system. Our civil society is held together by laws supported by legal research. If citizens are deprived of due process, then they are forced to become a law unto themselves or become the prey of those with money.

What is the definition of “legal outcome-based research?” I had no idea after reading the proposed change. Legal outcome-base research in our judicial system made as much sense as drawing square-based circles. Looking for clarity, I did a limited amount of legal research.

Result 1: “Legal Outcome-Based Research” Google:
Outcome Based Jurisprudence by Graydon Head & Ritchey LLP
“There are two ways for a court to decide a case. It can hear the facts, research the law and arrive at a conclusion based on that process. Using this method, the court has no idea how the case will turn out until the process plays itself out. In my naïve world, I like to think this is how it is supposed to work. “
“The other method is for the court to determine in advance what it wants the result to be and then find a way to get there. I call this “outcome based” jurisprudence. And I hate it. It is a type of “ends justifies the means” cynical approach to the law.”
(https://www.lexology.com/...a-ba27-b76910cd2404)

Then I did some general word research:

Result 2: “Outcome-Based Research” Google: Simply Educate Me website revealed:
”The truth is, outcome-based research is a wordplay from outcome-based education.”
“Outcome-based research starts at the goal, then works back to identify the steps required to achieve the pre-set goal.”
(https://simplyeducate.me/...ome-based-research/)

Results 3: “Outcome-Based Research” Google:
“Outcomes research is a broad umbrella term without a consistent definition.”
(https://pubmed.ncbi.nlm.nih.gov/12603584/)

Since “Outcome Research” is without a consistent definition and “outcome based” jurisprudence is when the court determines the case prior to hearing the facts, it is no wonder the definition is difficult if not impossible to understand.
Why would anyone base a legal document on “legal outcome-based research?”

Legal Research is a different matter. LDPs routinely research laws, proper forms, court rules, court locations, case history and other important facts to educate clients about their case. This is far from advice or opinion. It is simply providing factual information based on the law. The client uses that information to form their own opinion on what to do. If they need help forming an opinion, they need an attorney.

When a definition is not clear, concise, and usable, it could be defined as “worthless.” However, if the goal is confusion designed to trap someone doing something legally right and then define the act as being wrong it could have nefarious value. Based on many of the comments presented, this appears to be the motivation. It reminds me of a quote:
Henry David Thoreau once stated, “Any fool can make a rule, and any fool will mind it.”

The proposed change will mean a trained and qualified Legal Document Preparer will no longer be unable to “draft substantive legal motions, supporting memoranda, or appellate briefs that a client might possibly use in their case to advocate for a proper outcome in their matter before the court.” The sole reason given for the change is because, “Legal outcome-based research is required to draft” said document. That client advocating for his case is likely unable to afford an attorney. No money - No Justice

Since the only thing clear about the proposed “Definition” is simply that it is not clear and the meaning is without meaning perhaps it would be wise not to adopt it. This is a poorly written and dangerous change in the rules that benefits no one and unjustifiably harms the public. The disadvantaged will be deprived of the legal system. It will only make our legal system in Arizona the “best that money can buy.” Is that what you really want?

THE PROPOSED CHANGES BEFORE THIS BOARD ARE VERY MISLEADING:

1. The proposed definition change in Section 7-208(A) is not a new definition of “Legal outcome-based research.” It seems to be a convoluted prohibition under the thin veil of a definition to make it wrong for a “Legal Document Preparer” to prepare legal documents for disadvantaged people. Therefore, disadvantaged people will no longer have access to the legal system.

2. Why not just remove a few words from the current definition to make the intent clear:
“Legal Document Preparer” means secretarial or receptionist service without the supervision of an attorney.


Rick Rose
AZCLDP # #81714