I have owned Divorce Packet Processing LLC since 1989 and have been a certified Legal Document Preparer since 2003, one of the first certified under the court’s Legal Document Preparer (LDP) program. Further, I was one of the four non-lawyers appointed by the Supreme Court to the ad hoc committee that drafted the very rules governing legal document preparers. And thus am privy to both the court’s intent in organizing the LDP program and the discussions held when writing our code. And can say without a doubt that this amendment goes against both.

The program came about because of complaints not by consumers but by members of the bar, allegedly in the name of consumer protection. However, the complaints were few and far between. And it was easily seen that the complaints were more an attempt for attorneys to maintain their monopoly on providing legal assistance. Fortunately, the court saw through this and sought a means to both protect the public but at the same time provide reasonable legal assistance to them. And this amendment appears quite the same situation. As to the best of my knowledge, there have been NO complaints by any member of the public about the preparation and/or processing of a QDRO.

Administrative Order No. 2003-14 states “The Court recognizes the need to protect the public from possible harm caused by nonlawyers providing legal services MUST (emphasis added) be balanced against the public’s need for access to legal services.” (Said balance also in ACJA 7-208.) However, this amendment does the exact opposite.

Yes, when we drafted the code there was concern how to best achieve that balance and what, if any, documents LDP’s would be limited to. And, yes, QDROs were discussed. However, it was agreed by the entire committee, both the non-lawyers and lawyers, that rather than specify what documents an LDP may or may not prepare (as the list could be both extensive and ever changing), we concluded it best to write the rules in a way that would leave it to the individual document preparer to decide what documents he or she could individually prepare while sticking to the rules. So knowing where that line is between providing general legal and general factual information and providing legal advice specific to one particular matter. And of course if it was seen that they had crossed the line, proper action could be taken.

But in regards to this proposed amendment and the preparation of QDROs, it doesn’t seem any LDP has crossed that line. Or if I missed it in reviewing the LDP board meeting minutes, it isn’t a large number. Not one that warrants this proposed complete ban of LDPs preparing QDROs.

How can an LDP prepare a QDRO without crossing that line from providing general legal and general factial information to providing legal advice specific to one particular matter? I don’t know, as I’m not an LDP who prepare QDROs. But it seems neither are the ones behind this amendment. And the only ones who can properly answer that question would be actual LDPs who prepare them. As they would know both the rules they must adhere to and how they’re able to prepare a QDRO while adhering to same.

Yes, the line is a fine one, but so was the whole concept of LDP’s in the first place.
And it seems we’re right back where we were before 2003. When there were concerns expressed not by the public or even the courts, but by attorneys concerned about losing their monopoly of the legal process. And now we’ve got a proposed ban on LDPs preparing QDROs, with the same concerns being expressed. Concerns, once again, not expressed by the public, the courts, any retirement plan administrators, or anyone affected by any QDRO, but expressed by a workgroup of “experts”. Not experts made up of LDPs who prepare QDROs, but rather attorneys and legal paraprofessionals. The very same people affected financially by LDPs preparing QDROs. And thus wanting a monopoly of the process.

Perhaps that may not be the case. Perhaps these workgroups do have the best of intentions. But it does not appear that way. And scarily sets precedence for how alleged “experts” may dismantle our program. So for appearance’s sake (and, yes, the public would be made aware that this was done without proper experts), to show that what is being done is to protect the public and any assessment is in the public’s best interest, these workgroups MUST include a good number, even a majority, of LDPs who regularly prepare QDROs. As they are the true experts. And are the only ones who can answer how they’re able to do the work they do without crossing that line.

So just like before, the group making a recommendation to the court about this matter must include not just attorneys or even legal paraprofessionals, but LDPs who prepare QDROs. And also speak with members of the public who have received services by LDPs preparing QDROs, court personnel who have seen QDROs reviewed by the court and filed, and retirement plan adminstrators who process QDROs.

By utilizing these experts’ opinions and assessment of this issue, then and only then, can we continue to adhere to the very intent of the court and the Legal Document Preparer Program as a whole. Anything less deviates from that intent. And is not in the public’s best interest, doing it far more harm than good.

Thus I request that the current proposed amendment to 7-208 be rejected at this time.

Respectfully submitted,
Linda Seger, AZACLDP #80290

Lupita Flores Shestko-Montiel
Arizona Certified Legal Document Preparer # 80067
IRS: Registered Tax Return Preparer and
AZ Licensed Insurance Agent
Former FINRA Licensee (Allstate)
648 N Stone Avenue
Tucson, Arizona 85705-8349
Telephone: (520) 882-0212; e-mail: Lshestko@ aol.com

Date: August 07, 2025
1. Re: Public Comment Opposing Proposed Amendment to ACJA § 7-208 – QDRO Prohibition
2. To Whom It May Concern,
3. I am writing to respectfully oppose the proposed amendment to ACJA Section 7-208, which would prohibit Certified Legal Document Preparers (CLDPs) from preparing Qualified Domestic Relations Orders (QDROs).
4. I have been a Certified Legal Document Preparer since the inception of the program in 2003, and my license number AZCLDP # 80067, reflects my long-standing history. I have had many insurance licenses since 1984.
5. As a CLDP, Registered Tax Return Preparer, and licensed insurance professional, I bring a deep understanding of the financial, tax, and administrative implications of QDROs. During my tenure as an Allstate Agent, I also held a FINRA license, which gave me the skills to navigate complex retirement and investment-related matters. These qualifications uniquely equip me to assist clients with QDRO preparation in a manner that is both competent and ethical—within the current scope allowed under ACJA 7-208.
6. In Pima County, I’ve seen firsthand that family law judges regularly refer litigants to attorneys for QDRO preparation. Unfortunately, these referrals often impose an unnecessary financial burden. Attorneys typically charge $400 per hour, with minimum retainers starting around $3,000-$5000, only to use standard QDRO templates themselves. Worse, many attorneys fail to follow through with completing or filing the orders, leaving clients without closure or proper division of retirement assets.
7. That’s precisely why I became involved in helping litigants prepare QDROs. The process is largely administrative and relies on data from the dissolution decree, court orders, and plan administrators' model templates. In most cases, QDRO preparation does not require legal interpretation or litigation, but rather accurate and careful form completion—something well within the scope of qualified CLDPs.
8. Restricting CLDPs from preparing QDROs would:
9. Deny access to affordable, competent document services for many Arizonans;
10. Contradict the state’s Access to Justice initiative;
11. Remove a valuable public service that has never been shown to cause harm;
12. Favor a narrow group of legal professionals at the expense of litigants—particularly lower-income individuals.
13. I urge the Arizona Supreme Court to reject the proposed amendment. A better approach would be to enhance training or establish clearer guidelines for QDRO preparation under the existing CLDP framework—not eliminate this vital service altogether.
14. Respectfully,

15. Lupita Flores Shestko-Montiel, AZCLDP #80067

Public Comment in Opposition to the Proposed Amendments to ACJA §7-208 Regarding QDRO Preparation

Submitted by: Jessica Worley, AZCLDP #81548

I, Jessica Worley, a Certified Legal Document Preparer in the State of Arizona, respectfully submit this comment in opposition to the proposed amendments to ACJA §7-208, which would prohibit Certified Legal Document Preparers (LDPs) from preparing Qualified Domestic Relations Orders (QDROs).

As someone who has worked extensively in this area, I strongly oppose the claim that QDRO preparation inherently involves the unauthorized practice of law. These amendments appear to be driven by the opinions of workgroups composed exclusively of attorneys and legal paraprofessionals, with no inclusion of experienced LDPs or relevant stakeholders. I find it troubling that those most qualified to speak on this issue—those of us who have been successfully preparing QDROs for years without complaint or harm to the public—were not consulted.

The process of preparing a QDRO is generally straightforward and highly structured. In most cases, it involves using a model template provided by the plan administrator with minimal variables, all of which are derived from the parties’ divorce decree, a property settlement agreement, or basic factual information provided by the plan participant. These are fill-in-the-blank forms. There is no legal analysis required or legal strategy involved—just precision, attention to detail, and a thorough understanding of the process.
We do not believe that attorneys should have exclusive rights to prepare QDROs. In fact, we feel this way because, in practice, attorneys are rarely the ones preparing them at all. Much like how a doctor doesn't draw your blood or hook up your IV, attorneys typically hand this work off to paralegals or clerical staff—if they even offer the service. In my experience, the role of attorneys in QDRO preparation is largely symbolic or absent altogether.

To further illustrate this point, I have personally received numerous calls—from attorneys themselves—asking whether we prepare QDROs and how much we charge. These attorneys openly admit that they do not want to handle QDROs, nor do they have the infrastructure to do so. This proposed amendment would not transfer QDRO preparation from LDPs to attorneys—it would simply eliminate access to the service altogether for countless families who need it and cannot afford high attorney fees.
Let us also not forget that this change would fly in the face of Arizona’s broader efforts to expand access to justice. LDPs offer affordable, competent, and ethical document preparation services to the public. There is no record of widespread harm or misconduct arising from our preparation of QDROs. On the contrary, thousands of QDROs have been prepared successfully by LDPs across the state, and plan administrators have accepted them without issue.

In sum, this proposal seeks to solve a problem that does not exist—while creating a very real one by stripping the public of an accessible and affordable service. Without LDPs, many families will be forced to go without a QDRO, forfeiting their rightful retirement benefits simply because no one else will help them.

For all these reasons, I respectfully urge you to reject the proposed amendments to ACJA §7-208 and allow Certified Legal Document Preparers to continue offering QDRO preparation services within the scope of our certification.

Respectfully submitted this 7th day of August, 2025

Jessica Worley, AZCLDP #81548

I, Donald F. Steward, offer public comment to augment my previous comments in opposition to the proposed amendments to ACJA Section 7-208 to prohibit Certified Legal Document Preparers from preparing Qualified Domestic Relations Orders (QDROs).

Previously submitted comments note the fact that there were no Certified Legal Document Preparers (LDP’s) or other stakeholders involved in the two work groups that developed this random and unwarranted proposal. I have since become aware that a vague reference to some type of proposed rules change was noted in the agenda for the May 19, 2025, meeting of the Board Nonlawyer Legal Service Providers (the Board). This is grossly insufficient notice to the general public and LDP community.

It seems to be lost on the sponsors of this proposal that these proposed changes to 7-208 would remove a critical low-cost service that LDPs have been providing to thousands of people in the general public for over twenty-two years. Moreover, the proposal is in direct conflict with the Chief Justice’s five-year strategic agenda for Arizona’s judicial branch, which includes expanding access to justice, specifically expanding (not reducing) the services LDP’s are authorized to provide (see especially Goals 1.2 and 1.4).

What is further offensive about the proposal and how it is being processed, is that it is completely dismissive of the impact it will have on many LDPs who are small business owners who have dedicated years to developing their QDRO-related business in Arizona. This LDPs rely on the income stream to support themselves and their families. It further confirms the perception that the Certification and Licensing division at the Court has no respect or consideration for LDPs as competent legal professionals. This is further evidenced by the fact that there were reportedly at least two work groups involving Legal Paraprofessions to develop a plan for them to begin providing QDRO-related services, while only a vague note in the agenda of the LDP Board meeting has been presumed sufficient to prohibit LDPs from providing the QDRO-related services they have provided for decades.

For the above reasons, I request the proposal be rejected. Regardless, LDPs and the general should rest assured that this proposal will soon become a public relations matter, and LDPs will take whatever legal action available to protect their rights if this matter proceeds.

Thank you for your consideration.


Respectfully submitted this 24th day of July, 2025

Donald F. Steward, AZCLDP #80339

I am told that the filers of this proposed amendment "gave notice" of it by presenting it to the Board of this program, which the filers claim, then approved the amendments without comment.

There is no specific reference to this happening in the minutes of that meeting. No notice was given to the certified legal document preparers of such "notice".

There is no indication of its filing on the website of the Court.

No LDPs, of my knowledge, were aware of its filing until about two weeks ago.

This proposed amendment is in complete opposition to the Supreme Court's alleged efforts to increase "access to justice" in Arizona.

No justification has been given for this amendment other than the filers' allegations that they think "preparing QDROs is the practice of law".

LDPs have been successfully preparing QDROs for over 20 years at much lower prices than lawyers. Hmmm. Maybe that is the real motivation for this proposed amendment.

This proposed amendment should be rejected.