From: Janice Mulligan
Sent: Tuesday, November 11, 2008 7:41 PM
Subject: RIN # 3064--AD37
The purpose of this email is to voice an objection
to the exclusion of IOLTA accounts from the TLGP. Lawyer Trust Accounts (IOTLA)
are transactional accounts and generate interest to a third-party non
profit program that provides grants for much needed legal aid.
The failure to include IOLTA accounts in the TLGP
puts attorneys such as myself in a terrible predicament. My primary duty is
to my clients and as such, unless IOLTA accounts are protected under the
TLGP, I must move my client's trust money to fully insured non-interest
However, as an officer of the court, I know that
this results in a huge blow to legal aid at a time when such funds are
sorely needed. In addition, because the trust accounts may be moved to fully
insured but non-interest bearing accounts, the banks will reap an unintended
windfall by retaining money that should be paid out in interest.
Please reconsider this unjust decision, and allow
IOLTA funds to become a part of the TLGP. It is the only right thing to do
so that justice may be served.
Janice F. Mulligan
MULLIGAN & BANHAM
2442 4th Avenue, Suite 100
San Diego, CA 92101