Rick Grenz, Chief
Regulation and Policy Management Branch
Department of Corrections
P.O. Box 942883
Sacramento, CA 94283
Fax No. (916) 322-3842; Email: RPMB@executive.corr.ca.gov

Dear Mr. Grenz:

We are greatly relieved that your office listened to the hundreds of family members who wrote letters protesting the first set of proposed visiting regulations and attended the March 8, 2002 hearing. Many of the offensive regulations were dropped from the visiting rules. However, in their place, is a new set of amendments which if passed will effectively deny prisoners their right to legal services and advocacy.

Strike All of the New Wording of Section 3178 - Attorney Visitations and Consultations

1. Certification provisions for paralegals, legal investigators and law students will make it impossible for most legal agencies to utilize attorney representatives and conduct their legal work. Very few paralegals or employees are "certified." Attorneys should be able to utilize employees, students, and volunteers to conduct legal visits as long as they are sponsored by an attorney.
2. Most prisoners do not have "attorneys of record" or ongoing cases. This amendment would make it impossible for attorneys to investigate prisoner complaints regarding treatment, care and confinement issues. Attorneys and their representatives with signed legal visiting forms should be allowed to visit with prisoners.
3. These amendments criminalize legal services and legal access for prisoners.
4. These amendments violate attorney-client confidentiality and will discourage law firms and legal workers from providing needed services to prisoners.

These amendments are substantive and warrant a public hearing. Further, we demand that the public comment period be extended at least 45 days until the date of the hearing. These new amendments to the visiting rules are a frontal assault on the right of prisoners to seek legal counsel and to meet with attorneys and their representatives.

Sincerely,

Name:

Address:

City, State, ZIP