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IDY.LLLT.Com Limited License Legal Technician IDY.LLLT.com Limited License Legal Technician April 17, 2021 Honorable Justices of the Washington State Supreme Court P.O. Box 40929 Olympia, WA 98504-0929 RE: Public comments regarding sunsetting of LLLT license submitted prior to onset of official public comment period Dear Honorable Justices: I write to ensure that comments submitted to the Court after its letter decision of June 5, 2020 to sunset the LLLT license, and before the official public comment period opened in January 2021, are properly accounted for in the public record and considered by the Court. In all, there were 60 comments in opposition to the sunsetting of the LLLT license as follows: WA Citizens: 17 LLLTs and LLLT students: 25 Colleges: 5 LLLT clients: 6 Legal organizations: 4 Attorneys: 3 Those letters and emails are summarized in a table on the following pages and are attached as pp. 1 – 135 to this letter. Sincerely, Christine M. Carpenter, LLLT myLLLT.com · 2367 Tacoma Ave S, Tacoma, WA 98402 · (253) 457-0967 Date of submission Name of commenter Page number WASHINGTON CITIZENS Undated Holly Hess 1 6/15/2020 Catherine Paxton 2 6/17/2020 Judith Potter 3 6/20/2020 Gena Di Labio 4 6/20/2020 Teresa Dix 6 6/25/2020 Kristi Gresham 7 6/25/2020 Nancy L. 8 6/25/2020 Penelope Guntermann 10 6/28/2020 Mary Waggoner 11 7/1/2020 Teresa Dix 12 7/2/2020 Pam Madison 13 7/3/2020 Joan Riedel 14 7/5/2020 Sally Lider 15 7/16/2020 Ann Brooking 16 7/16/2020 Donna These 17 8/8/2020 Rose Ness 19 LLLT STUDENTS AND LLLTs 6/6/2020 Kristina Williams 21 6/10/2020 Jennifer Kobayashi 23 6/11/2020 Angela Guadamuz 24 6/11/2020 Lena Robell 26 6/11/2020 Michael Begley 27 6/12/2020 Olivia Schroder 29 6/13/2020 Laura Mclean 30 6/13/2020 Stacy Davis 32 6/17/2020 Charity Rotinski 33 6/17/2020 Cynthia Silva 35 6/18/2020 Sherri Donley 36 6/22/2020 Stacy Davis 38 6/24/2020 Connie Major 41 6/25/2020 Tina Palazza 44 6/26/2020 Angela Wright 48 6/29/2020 Carol Peterson 52 6/29/2020 Highline students (signed by 16 students) 53 2 | Page 7/1/2020 Alaina Slater 56 7/4/2020 Melinda Jackson 57 7/4/2020 Melissa Albert 60 7/11/2020 Ranae York 67 7/28/2020 Elissa Dunsmore 68 8/30/2020 Heather Christopher 70 10/16/2020 Lisa Alison 71 COLLEGES 6/10/2020 Whatcom Community College 73 6/11/2020 Tacoma Community College 74 6/12/2020 Spokane Community College 76 6/19/2020 Edmonds College 78 7/1/2020 Whatcom Community College 83 LLLT CLIENTS 6/12/2020 Yesenia Avelar 85 6/15/2020 Leonard McDonald 86 6/22/2020 Judy Stilson 87 6/26/2020 Chantel Turner 88 6/29/2020 Billie Murray 90 7/21/2020 Elizabeth Lemon 93 LEGAL ORGANIZATIONS 6/19/2020 WSBA LLLT Board 94 7/17/2020 Pro Bono Council 120 8/19/2020 WSBA ATJ Board 124 Undated WSBA Low Bono Section 126 ATTORNEYS 6/17/2020 Kathryn Berger 130 7/1/2020 Alton McFadden 133 7/1/2020 Penny Henderson 134 3 | Page Dear Justice Johnson, I am a resident of the State ofWashington. I email you today to notify you of my disappointment regarding the sunset of the LLL T licensure, on the basis of the below considerations: Cost - The program was 1 % of the WSBA's overali budget. More money was spent on publications and board members travel then the entire administration of this program. Rules - The Court did not have public comment or get input from stakeholders. This is not the access the justice the Court has been posting on social media. Disparate impact - this decision by the Court has a disparate impact on persons of color and those of lower income - the very ones you took an oath to help. In this time of economic stress and political unrest, centered on racial disparities in access to justice, this was a particularly poor decision for the we!!-being of the people of Washington. Legal representation is economically well out of the reach of most people, especially but not limited to those with statistically lower incomes i.e. women and people of color, and the LLL T Program provided a path to remedying that issue. Furthermore the LLLT licensure has potential to raise profits for the legal industry, for example a firm employing an LLLT would be able to bring in more business, since people who otherwise couldn't afford legal fees (and would simply forego legal assistance) would now be able to pay for the LLLT's services. If there was not enough participation in the program, that should be remedied by promotion of the program, not by ending it. If there is good reason to end the program (inefficiency etc.) it shouid be replaced by an alternative program or plan - unfortunately there is no 'pian B', whiie all the efforts -and considerntion put towards creating a valid license, with educational and experience requirements commensurate with its limited scope, have been washed away suddenly with no public comment. i ask thai: you reconsider i:his decision. Sincerely, Public comments in opposition to sunsetting of LLLT license 1 of 135 From: OFFICE RECEPTIONIST, CLERK To: Carlson, Susan; Lennon, Erin Subject: FW: LLL-T need support Date: Wednesday, July 15, 2020 12:34:00 PM From: TheCathpax . [mailto: ] Sent: Wednesday, July 15, 2020 12:30 PM To: OFFICE RECEPTIONIST, CLERK <[email protected]> Subject: LLL-T need support People need legal help all the time, but they often can't afford the costs of an attorney. LLL- T's fill a need which many more people can access. Please do not do away with the program as it is very valuable. Sincerely, Catherine Paxton Arlington, WA -- Public comments in opposition to sunsetting of LLLT license 2 of 135 Dawson, Seth From: Sent: Wednesday, June 17, 2020 7:59 AM To: Carlson, Susan Subject: Limited License Legal Technician future Dear Susan, I am a recent community member addition to the Limited License Legal Technician Board (LLLT Board). I was asked to join the Board because of my 30-year business career experience. I had heard about the LLLT license but it was not until I was on the Board that I learned the extent and depth of the program and all of the work the Board has done. I think the Court's decision to sunset the program for financial reasons should be reviewed. The Board of Governors did not require the LLLT Board to even consider becoming budget neutral until January of 2020. That was not enough time for the Board to increase marketing or find other funds. If the license is sunset, the program should be given a year or two to explore alternative funding. Even Governor Grabecki said the Budget Committee was not being fair by making such immediate demands without giving us an opportunity to explore alternatives. Just when the obstacles were being overcome and the program was on the verge of clearing the way for more students to get through the difficult and rigorous education required for the program, the rug has been pulled out from beneath them. There was no warning or recourse after many colleges have invested in developing the curriculum. This rash decision by the court looks very unfair to the community. The court might rethink the target population for LLLTs. It is still an access to justice or access to the courthouse issue to have people of moderate means be able to navigate the courthouse legal system with LLLT assistance. Middle income people can barely afford an attorney, especially those who are working poor. Working poor and people of moderate means have virtually no programs to provide them with the means to meet their civil legal needs. You have given the LLLT Board an almost impossible task – to find a way to have a poverty population support their own legal services. They have almost done that by providing for limited services to people in other income brackets. Where legal aid funds immediate legal assistance, the LLLT program leverages the education and experience by providing legal services for a minimal overhead cost compared to the benefits. We are aware that attorneys are threatened by the presence of this growing field and demand for access, however those in power who have shot this down have a conflict with the very essence of the program. The Board has worked hard to balance the Court’s and the legal community’s requests – have a program where the practitioners are qualified and educated, offering some security in the integrity of the license. The approximate four- year process to become a LLLT makes the immediate demand for more LLLTs to be licensed and in the pipeline difficult. Please give the LLLT Board more time to explore marketing and funding. At a minimum please give the students and candidates in the pipeline a more reasonable amount of time to finish their program. Thank you for your consideration, Judith Potter 1 Public comments in opposition to sunsetting of LLLT license 3 of 135 From: OFFICE RECEPTIONIST, CLERK To: Carlson, Susan; Lennon, Erin Subject: FW: Decision regardingLimited-License Legal Technician Program Date: Monday, June 22, 2020 8:19:26 AM From: dilabiog dilabiog [mailto: ] Sent: Saturday, June 20, 2020 5:03 PM To: OFFICE RECEPTIONIST, CLERK <[email protected]> Subject: Decision regardingLimited-License Legal Technician Program Dear Justices: It has come to my attention that the Supreme Court of Washington has decided to end the Limited License Legal Technician Program, (LLL-T) which provides professional, affordable, legal support to those of low- income and minority populations.
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