BILL ANALYSIS Ó
SB 270
Page 1
Date of Hearing: June 21, 2016
ASSEMBLY COMMITTEE ON BUSINESS AND PROFESSIONS
Rudy Salas, Chair
SB 270(Mendoza) - As Amended June 14, 2016
NOTE: This bill is double referred, and if passed out of this
Committee, it will be referred to the Assembly Committee on
Judiciary.
SENATE VOTE: 29-9
SUBJECT: Court Reporters Board of California: civil actions:
registered corporations
SUMMARY: Authorizes the Court Reporters Board of California
(CRB) to bring a civil action, or request the Attorney General
(AG) to bring an action in a superior court to enjoin any person
or corporation, from arranging for court reporter services in
this state without being registered with the CRB, as specified,
and allows for specified penalties; requires, beginning January
1, 2018, any corporation organized under the laws of this state
or under the laws of another state that arranges for the
services of shorthand reporting to register with the CRB;
requires the CRB to establish a registration process; authorizes
the CRB to take disciplinary action against a registered
corporation for acts of unprofessional conduct, as specified;
requires a corporation to appoint an individual in this state to
act as a designated representative and would require the
designated representative to hold a valid certificate as a
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certified shorthand reporter in this state or to pass an
examination administered by the CRB; and, authorizes the CRB to
charge a fee for the registration of a corporation.
EXISTING LAW:
1)Provides for the regulation and certification of shorthand
reporters by the CRB within the Department of Consumer Affairs
(DCA). (Business and Professions Code (BPC) Section 8000, et
seq.)
2)Prohibits a person from engaging in the practice of shorthand
reporting, as specified, unless that person is the holder of a
certificate in full force and effect issued by the CRB unless
he or she is a salaried, full-time employee of any department
or agency of the state who is employed as a hearing reporter.
(BPC Section 8016)
3)Defines the "practice of shorthand reporting" as the making,
by means of written symbols or abbreviations in shorthand or
machine shorthand writing, of a verbatim record of any oral
court proceeding, deposition, court ordered hearing or
arbitration or proceeding before any grand jury, referee, or
court commissioner and the accurate transcription, thereof.
(BPC Section 8017)
4)Specifies that nothing requires the use of a certified
shorthand reporter when not otherwise required by law. (BPC
Section 8017)
5)Except as specified, prohibits a person, firm or corporation
from assuming or using the title "certified shorthand
reported" or the abbreviation "C.S.R." or using any words or
symbols indicating or tending to indicate that he, she, or it
is certified. (BPC Section 8018)
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6)Provides the CRB, in addition to its authority to conduct
disciplinary proceedings, the authority to issue
administrative citations or assess fines for the violation of
any rules and regulations adopted by the CRB. (BPC Section
8027.5)
7)Defines a "shorthand reporting corporation" as a corporation
which is authorized to render professional services, as
specified in the Corporations Code (CORP) Section 13401, as
long as that corporation and all of its shareholders,
officers, directors, and employees rendering professional
services who are certified shorthand reporters are in
compliance with specified requirements in the Corporations
Code. (BPC Section 8040)
8)Specifies that each director, shareholder, and officer of a
shorthand reporting corporation must be a licensed shorthand
reporter. (BPC Section 8044)
9)Prohibits a shorthand reporting corporation from doing or
failing to do any act which would constitute unprofessional
conduct under any statute, rule, or regulation which pertains
to shorthand reporters or shorthand reporting. (BPC Section
8046)
10)Requires a shorthand reporting corporation in conducting its
practice to observe and be bound by statutes, rules, and
regulations to the same extent as a person holding a license.
(BPC Sections 8046)
11)Requires every person under the jurisdiction of the CRB who
holds a license or certificate, or temporary license or
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certificate, or business that renders professional services,
namely shorthand reporting services, within the meaning of
CORP Section 13401, to comply with professional standards of
practice, as specified. (California Code of Regulations Title
16 (16 CCR) Section 2475)
12)Defines "professional services" to mean any type of
professional service that may be lawfully rendered only
pursuant to a license, certification, or registration
authorized by the BPC, the Chiropractic Act, or the
Osteopathic Act. (CORP Section 13401(a))
13)Defines "foreign professional corporation" to mean a
corporation organized under the laws of a state of the United
States other than this state that is engaged in a profession
of a type for which there is authorization in the BPC for the
performance of professional services by a foreign professional
corporation. (CORP Section 13401(c))
14)Defines "professional corporation" to mean a corporation
organized under the General Corporation Law, as specified,
that is engaged in rendering professional services in a single
profession, except as otherwise authorized, pursuant to a
certificate of registration issued by the governmental agency
regulating the profession as herein provided and that in its
practice or business designates itself as a professional or
other corporation as may be required by statute. However, any
professional corporation or foreign professional corporation
rendering professional services by persons duly licensed by
the Medical Board of California or any examining committee
under the jurisdiction of the board, the Osteopathic Medical
Board of California, the Dental Board of California, the
Dental Hygiene Committee of California, the California State
Board of Pharmacy, the Veterinary Medical Board, the
California Architects Board, the Court Reporters Board of
California, the Board of Behavioral Sciences, the
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Speech-Language Pathology and Audiology Board, the Board of
Registered Nursing, or the State Board of Optometry is not be
required to obtain a certificate of registration in order to
render those professional services. (CORP Section 13401(b))
THIS BILL:
15)Provides that on and after January 1, 2018, any corporation
organized under the laws of this state or under the law of
another state of the United States, that is qualified to do
business in this state, may arrange for services of shorthand
reporting in this state, without complying with specified
requirements, if that corporation is registered with the CRB,
as specified, and corporations registered with the CRB will be
referred to as a "registered corporation."
16)Requires the CRB on and after January 1, 2018, to implement a
registration process, as specified.
17)States that any law or regulation applicable to a licensee is
also applicable to a registered corporation arranging for the
services of shorthand reporting, as specified.
18)Considers a corporation or other entity to be arranging for
the services of shorthand reporting in this state if it does
any of the following:
a) Coordinates or performs any act that would otherwise
constitute an obligation owed by a certified court reporter
in the state to the parties in any reported proceeding;
b) Determines the amount billed to the parties in a
proceeding for any court reporting services performed in
this state;
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c) Recruits a resident of this state to provide court
reporting services or shorthand reporting services; or,
d) Performs any services related to the duties of a
certified court reporter.
19)States that a corporation registration may be suspended,
revoked, or denied and other disciplinary action may be
imposed if the registered corporation or any of its officers,
agents, or employees perform any act that constitutes
unprofessional conduct when arranging for any services of
shorthand reporting; and, specifies that unprofessional
conduct includes, but is not limited to, an act contrary to
the professional standards concerning confidentiality,
impartiality, filing and retention of notes, the notification,
availability, delivery, execution, and certification of
transcripts, or any law related to the duties of a court
reporter.
20)States that on and after January 1, 2018, it is unlawful for
any corporation, whether foreign or domestic, to arrange for
services of shorthand reporting, or to advertise or put out
any sign, card, or other device that may indicate to the
public that it is entitled to arrange for services of
shorthand reporting without first registering with the CRB.
21)Requires a corporation registering with the CRB to file an
application with the CRB on a form prescribed by the CRB.
22)Requires the application for registration to include, but not
be limited to the following:
a) The federal identification number of the applicant;
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b) The name of the individual who will be appointed as a
designated representative of the applicant, and any other
identifying information, as specified;
c) Any required fee; and,
d) All information required to complete the application.
23)Requires on and after January 1, 2018, each registered
corporation arranging for services of shorthand reporting to
appoint an individual in this state to act as a designated
representative, who may hold a valid certificate as a
shorthand reporter or pass an examination administered by the
CRB.
24)Requires the CRB, by January 1, 2018, to administer an
examination to determine whether a designated representative
of a registered corporation understands the ethics and
professional conduct required for the practice of court
reporting in this state, the laws and regulations applicable
to court reporting in this state, and the obligations owned by
a certified court reporter in this state to the parties in any
reported proceeding.
25)Requires the CRB to issue a certificate to a designated
representative.
26)Authorizes the CRB to revoke the certification of a
designated representative for any violation of the laws or
regulations applicable to a licensee, if the certificate of an
appointed designated representative is revoked, the registered
corporation that appointed that designated representative is
in violation.
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27)Permits the CRB, in addition to any other authority or
remedy, to bring a civil action in a superior court to enjoin
any person or corporation organized under the laws of this
state or another state from arranging for court reporter
services in this state without being registered with the CRB
or without authorization to arrange for court reporter
services, as specified, in this state, and permits the CRB to
request the AG to bring an action.
28)States that if a civil action is brought, the court, in
addition to any other remedy authorized by law, must impose a
penalty of not less than $1,000 and no more than $2,500 per
day against the person or corporation rendering services
without a license or authorization, and the court, in addition
to any other restitution provided by law, may also order
restitution and the return of any payments made to the person
or corporation.
29)Authorizes the court, in addition to any other authority or
remedy, if an action is brought, to also enjoin a person or
corporation from taking any action that would otherwise
constitute a violation of any statute or regulation of the CRB
pertaining to impartiality, including but not limited to
violation of the professional standards of practice of the
CRB, and provides that the court, in addition to any other
penalty provided for by statute or regulation, may impose a
penalty of up to $2,500 and order restitution for any acts
undertaken by any person or corporation rendering court
reporter services in this state.
30)Requires the court in determining the amount of the penalty
referenced in 14) above, to take into consideration the
frequency of the violations and the impact of those
violations, as specified.
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31)Requires the court to award reasonable investigation and
enforcement costs to the CRB or the AG if an injunction is
granted, as specified, and also authorizes the court to award
a portion of any unallocated penalties collected, as
specified, to be used for future investigation and
enforcement, and requires any penalty awarded to the CRB to be
deposited in the Court Reporter's Fund, which is subject to
appropriation by the Legislature.
32)States that numbers 13)-17) above cannot be construed to
change, limit, or alter any existing authority of the board,
including existing injunctive authority.
33)Authorizes the CRB to establish a fee for a corporation to
register with the CRB in a fixed amount not to exceed the
reasonable regulatory cost of preparing and administering the
registration process.
FISCAL EFFECT: According to the Senate Appropriations Committee
Analysis dated May 18, 2015, this bill will result in "unknown
additional CRB enforcement costs, dependent upon the number of
complaints investigated and enforcement actions. If additional
staff is needed, costs could be in the range of $100,000
annually." This bill will also result in "unknown additional
fine revenues, which are also dependent upon the number of
successfully adjudicated cases. In addition, there could be
reimbursements for enforcement and investigation costs that are
awarded by the courts."
COMMENTS:
Purpose. This bill is sponsored by the California Court
Reporters Association . According to the author, "[this bill]
strengthens the authority of the CRB to regulate or prevent
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unlicensed individuals and corporations from unlawfully
rendering court reporting services in California by issuing
fines or injunctions for acts in violation of the CRB's
professional and ethical rules for certified shorthand
reporters.
Under current law, the CRB has limited authority to impose
penalties on any court reporter or court reporting corporation
that is rendering services without a court reporting license.
However, for unlicensed entities, the CRB has had challenges in
imposing fines for any violations. This has jeopardized the
integrity of the court reporting profession and places at a
disadvantage licensed businesses that provide court reporting
services."
Court Reporters Board. The CRB is responsible for licensing and
disciplining certified shorthand reporters. Certified shorthand
reporters are responsible for reporting depositions in legal
cases as well as court proceedings. Since 1972, the CRB has
permitted the certification of individuals and at one time, the
registration of shorthand reporting corporations. Currently,
the CRB oversees approximately 7,000 certified shorthand
reporters. The CRB establishes the educational requirements for
certification including authorizing the minimal educational
standards and approving schools. In order to qualify for
licensure as a certified shorthand reporter, an individual must
have a high school education, twelve months (or 1,400 hours) of
full-time work experience related to making records of hearings,
obtain a passing score on the California State Hearing Reporters
Examination, and complete a course from an approved
court-reporting school. Currently, in California, certified
shorthand reporters work in two separate capacities: 1) as an
"official reporter" who works as a court reporter employed by a
state court, or 2) as a "freelance reporter" who is hired
privately by court reporting businesses, firms, or attorneys to
report depositions. Both official and freelance reporters are
required to meet the same educational and examination
qualifications. Currently, the CRB does not separately license
or register court reporting corporations.
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Enforcement Authority. In addition to the CRB's licensing
function, the CRB is also tasked with enforcement-related
activities for shorthand reporters who violate the practice act.
BPC Section 8025 states that a certificate to practice as a
shorthand reporter may be suspended, revoked, or denied, or
other disciplinary action may be taken against a certificate
holder for multiple reasons including the conviction of a
misdemeanor if the misdemeanor is substantially related to the
functions and duties of a court reporter, fraud or
misrepresentation in obtaining a certificate, unprofessional
conduct, or loss or destruction of stenographic notes that
prevents the production of a transcript, among others. In
addition to the provisions of BPC Section 8025, the CRB
specifies through regulation the professional standards of
practice (16 CCR Section 2475) for professionals, which include
acting without bias toward, or prejudice against, any parties
and/or their attorneys; not entering into, arranging, or
participating in a relationship that compromises the
impartiality of the certified shorthand reporter, including but
not limited to a relationship in which compensation for
reporting services is based upon the outcome of the proceeding;
and maintaining confidentiality of information, among others.
Under current law, the CRB has the authority to carry out its
licensing and enforcement authority against any person or
corporation, as defined in CORP Section 13401. According to the
author, the CRB has limited authority to impose penalties on any
court reporter or court reporting corporation that is rendering
services without a court reporting license. While the CRB does
not register or certify corporations in California, BPC Sections
8044 and 8046 provide the CRB with the explicit authority over
corporations incorporated in California because each director,
shareholder, and officer of a shorthand reporting corporation is
required to be a licensed shorthand reporter; however, the same
authority is not specified in statute for foreign corporations
providing or arranging for court reporting business in
California. This bill aims to increase the CRB's disciplinary
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reach to include those entities or corporations who may be
arranging for shorthand reporting services by permitting the CRB
to discipline entities who are in violation of professional
standards as regulated by the CRB, or other violations of the
practice act, and by establishing a certification process for
corporations who are arranging for shorthand reporting services,
but where each director, shareholder, or officer is not a
California licensed shorthand reporter.
Scope of Practice. BPC Section 8017 defines shorthand reporting
as the making by means of written symbols or abbreviations in
shorthand or machine shorthand writing, of a verbatim record of
any oral court proceeding, deposition, court ordered hearing or
arbitration , or proceeding before any grand jury, referee, or
court commissioner, and the accurate transcript thereof.
16 CCR Section 2403 further specifies that the practice of
shorthand reporting includes services for actions in superior
court such as delivering a copy of the original transcript in a
computer-readable form, as specified, labeling disks of
transactions with the case name and court number, and the dates
of the proceedings contained on the disk, among others. For a
deposition, 16 CCR Section 2403 includes making a full or
partial copy of a transcription available, notifying all parties
who attended a deposition of requests made by other parties for
either an original copy of the transcript, or any portion
thereof, and securely sealing the transcript in an envelope or
package, as specified.
This bill does not alter the current practice of shorthand
reporting; however, this bill requires corporations who arrange
for shorthand reporting services, which may include some of the
activities contained within the shorthand reporters' scope of
practice, to register with the CRB.
Professional Corporations and The Moscone-Knox Professional
Corporation Act (Act). BPC Section 8044 specifies that each
director, shareholder, and officer of a shorthand reporting
corporation must be a licensed shorthand reporter. Business
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models for shorthand reporting corporations and other service
providers vary throughout the state. While there are a number
of licensee-owned corporations in California, there are a number
of businesses that do not hold themselves out to be court
reporting corporations. These corporations claim to be
litigation service providers that only arrange for court
reporting services, but are not actually responsible for the
making of the written record.
There are several other regulatory entities under the DCA that
have established some form of registration or a licensure
programs for both foreign and domestic corporations. Those
entities include the Board of Pharmacy, the Bureau of Real
Estate Appraisers, and the Contractors State License Board,
among others.
According to the author, the need for this bill is in response
to the CRB's inability to take the appropriate disciplinary
actions against a corporation who was accused of operating in
violation of the CRB's professional standards of practice;
specifically, 16 CCR Section 2475(b)(8) which prohibits any
person or business under the jurisdiction of the CRB from either
directly or indirectly giving or receiving any gift, incentive,
reward, or anything of value to or from any person or entity
associated with a proceeding being reported that is more than
$100.
Court Reporters Board of California v. U.S. Legal Support, Inc.,
1-11-CV197817. In 2010, the CRB took disciplinary action
against a corporation, charging it with violating 16 CCR Section
2475(b)(8) by issuing a citation and fine. The corporation
argued that the CRB lacked the jurisdictional authority to issue
a citation to the company, and did not pay the fine.
As a result, a formal case was brought against U.S. Legal
Support, Inc. in 2012. The court held that the CRB lacked the
jurisdictional authority to issue citations and fines to an
out-of-state corporation rendering court reporting services in
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California without authorization to do so. As the court noted
in its decision, although U.S. Legal Services, Inc. was
rendering court reporting services in California and was in
violation of the gift giving rules as defined in the CRB's
regulations, there was no explicit authority in statute
authorizing CRB to impose citations or fines because the
corporation was not authorized to do business in California
under the BPC. In addition to other legal remedies, this bill
will authorize the CRB, under this new section, to bring an
action or request the AG to bring an action to enjoin any
unlicensed or unauthorized person, or any domestic or foreign
corporation from rendering court reporter services in this state
and in doing so, seek certain penalties including fines and
possibly restitution.
The issue of professional conduct was raised in the CRB's 2015
Sunset Review Report. As noted in the Committee Background
Paper, according to the CRB, additional complaints have been
received about overcharging for court transcripts, a violation
of Government Code 69950 and is direct consumer harm; the
overcharging of one party for transcripts is in practice
cost-shifting, or akin to giving a large gift. This is a
practice whereby a court reporting firm offers to charge the
noticing party a nominal amount if the noticing party chooses to
utilize the services of that firm. The costs of the transcripts
are then shifted over to the defending attorney(s), who has no
ability to choose the shorthand reporter and is essentially
stuck with the bill presented in order to obtain a transcript.
While the practice is not specifically illegal on its face, the
CRB is concerned about the serious ethical considerations that
arise out of this type of scenario. As a result, it is important
for the CRB to ensure that the same rules that apply to all
licensees that serve to protect consumers are enforced against
all entities that provide shorthand reporting services.
If a corporation is providing shorthand reporting services by
way of contracting with or hiring California-licensed court
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reporters and violates the professional conduct standards, then
this bill will specifically authorize the CRB to bring an action
(or request the AG to bring an action) to enjoin a corporation,
or corporation organized under another state, from rendering
shorthand reporting services in California without ever being
issued a license by the CRB or authorization to render court
reporter services in California. In addition, this bill would
authorize the CRB to collect specified penalties against
corporations who may be in violation. This bill also seeks to
establish a new registration process for corporations who
arrange for the services of shorthand reporting in order to
comply with the unprofessional conduct standards as specified
through regulation.
Current Related Legislation. AB 2192 (Salas, Hill) of the
current Legislative Session, extends the sunset date for the CRB
and its executive officer. Although the bill does not address
court reporting corporations, the issue was raised in the sunset
review hearing on March 9, 2016. STATUS: This bill is pending
in the Senate Committee on Business and Professions.
Prior Related Legislation. AB 1461 (Ruskin) of 2009, would have
prohibited a firm, partnership, sole proprietorship, or other
business entity providing or arranging for shorthand reporting
services, from doing or failing to do any act that constitutes
unprofessional conduct under any statute, rule or regulation
pertaining to shorthand reporters or shorthand reporting. NOTE:
This bill was held in the Assembly Committee on Appropriations.
ARGUMENTS IN SUPPORT:
The California Court Reporters Association writes in support,
"In response to last year's committee dialogue on this bill, SB
270 has been amended to also create a pathway for corporations
to lawfully arrange for shorthand reporting services in the
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state. Specifically, this bill allows a corporation, either
domestic or foreign, that is not headed by a licensee to
register with the board before arranging for any shorthand
reporting services in the state. This registration would ensure
that the corporation is under the jurisdiction of the board and
therefore must follow California law related to court reporting
services."
ARGUMENTS IN OPPOSITION:
Esquire Deposition Services, LLC , Magna Legal Services , U.S.
Legal Support, Inc. Veritext Corp , and Litigation Services write
in opposition, "As amended, [this bill] proposes a registration
scheme for companies which 'arrange' for services of shorthand
reporting in California. As drafted, this registration approach
has many of the attributes of traditional licensing, but the
language fails to answer basic licensing questions, such as
which companies can and must register, and which activities will
be subjected to regulation. There are basic terms which go
undefined, transition questions not answered, an examination
proposed with little detail, inaccurate descriptions of business
entities and more. Read literally, the bill could require
registration from an almost unlimited number of businesses."
POLICY ISSUES:
1) This bill seeks to create parity for licensee-owned
shorthand reporting corporations and those corporations
that are non-licensee owned to ensure that both types of
corporations are subject to the same enforcement standards.
Currently, the CRB can only take action against its
licensees, which leaves shorthand reporting corporations
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exempt from CRB oversight. It is unclear if this bill
solves the problem it is attempting to address.
BPC Section 8044 specifically requires that a shorthand
reporting corporation is entirely controlled by a certified
shorthand reporter or group of licensees. However, as currently
drafted, it is unclear if all corporations owned by a licensee
or not, would be required to register.
2) This bill permits a corporation to operate in California
and requires it to register with the CRB if they are
arranging for shorthand reporting services. As noted
earlier, the scope of practice for a shorthand reporter may
contain actions which may include merely arranging
shorthand reporting services. However, the larger question
of whether a corporation's action of arranging for
shorthand reporting services is considered within the scope
of practice of a certified shorthand reporter remains
unanswered in this bill.
IMPLEMENTATION ISSUES:
1) This bill will prohibit a corporation, whether foreign
or domestic, from arranging for shorthand reporting
services without first registering with the CRB; and, as
part of that registration process the corporation is
required to appoint an individual in this state as a
designated representative, which can be a licensee or a
person who has passed a CRB-administered examination. As
currently drafted, it is unclear what the enforcement
process is for revoking, suspending or placing other
probationary conditions upon a designate representative of
a corporation (given they are not a licensee). If the
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designated representative forcibly or voluntarily leaves
the corporation, can the corporation simply appoint a new
representative and unprofessional conduct can continue?
Additionally, if the corporation is found to have violated
provisions of the practice act, is the designated
representative the receiver of disciplinary action, if any?
The author may wish to clarify how the designated
representative can be disciplined.
2) As drafted, this bill refers only to court reporting
corporations. It is unclear if the intent of the bill is
address only corporations that provides shorthand reporting
services to the courts. The author may wish to clarify if
this bill is intending to capture all shorthand reporting
corporations.
AMENDMENTS:
In response to concerns raised above, the author may wish to
consider amending the bill to instead require all corporations
to abide by the prohibition on gift giving as specified in 16
CCR Section 2475(b)(8), and other ethical guidelines as is
required for all certified shorthand reporters, as follows:
(a) Any domestic or foreign corporation that offers to
arrange for or arranges for the services of shorthand
reporting as defined in Section 8017, whether through an
employee or an independent contractor, shall comply with
all of the following:
(1) Act without bias toward or prejudice against any
parties and their attorneys.
(2) Not enter into, arrange, or participate in a
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relationship that compromises the impartiality of the
certified shorthand reporter, including, but not limited
to, a relationship in which compensation for reporting
services is based upon the outcome of the proceeding.
(3) (A) Except as specified in subparagraph (B), not
directly or indirectly give or receive any gift,
incentive, reward, or anything of value to or from any
person or entity associated with a proceeding being
reported, including, but not limited to, attorneys or an
attorney's family members, employees of attorneys or an
employee's family members, law firms as single entities,
clients, witnesses, insurers, underwriters, or any agents
or representatives thereof.
(B) A corporation may:
(i) Receive compensation for the arrangement of
shorthand reporting services
(ii) Give or receive items that do not exceed $100 in
the aggregate for any combination of items given or
received per calendar year to or from an attorney or
an attorney's family members, an employee of an
attorney or an employee's family members, a law firm
as a single entity, a client, a witness, an insurer,
an underwriter, or any agent or representative
thereof.
(iii) Provide services without charge or compensation
for which the certified shorthand reporter reasonably
expects to be reimbursed from the Transcript
Reimbursement Fund, established in Section 8030.2, or
otherwise for an indigent person as defined in Section
8030.4.
(a) The board, the Director of Consumer Affairs, and the
Attorney General have jurisdiction to enforce the
provisions of this section.
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REGISTERED SUPPORT:
California Court Reporters Association (sponsor)
American Reporting Services, LLC
Northern California Court Reporters Association
The San Diego Superior Court Reporter Association
REGISTERED OPPOSITION:
Esquire Deposition Services, LLC
Litigation Services
Magna Legal Services
U.S. Legal Support, Inc.
Veritext Corp.
Analysis Prepared by:Elissa Silva /Gabby Nepomuceno B. & P. /
(916) 319-3301