[WSBARP] Can a Will Revoke a JTWROS

Wed Oct 27 12:59:14 PDT 2021

Technically that is true. But any will that does not adequately provide for a surviving spouse could be overridden by Ch. 11.54 RCW. The legislature raised the homestead amount to the median home price in that county, so a King County widow could request up to $749,000 as a homestead award if she is omitted from the Will.  The legislative intent is that widows would not be forced to sell their home or become homeless upon the death of their spouse.
To Jeff’s point, if there are step-children, the step-children can request to share in the homestead award. But widow would have a compelling argument to ask the court to carve out a life estate for her if that was not done in the will, and I have seen the courts do that (or send the parties to mediation, where that is the obvious solution to the step-children dilemma if careful planning was not done).
Best,
Nick

Nicholas Pleasants
Owner

[(Logo) Pleasants Law Firm]<http://www.pleasantslaw.com/>

Pleasants Law Firm, P.S.
2300 130th Ave NE, Suite A-101
Bellevue, WA 98005-1755
(425) 615-7070 tel/fax
nick at pleasantslaw.com<mailto:nick at pleasantslaw.com>
www.pleasantslaw.com<http://www.pleasantslaw.com>
The information contained in this e-mail message may be privileged and is confidential information intended only for the use of the recipient, or any employee or agent responsible to deliver it to the intended recipient. Any unauthorized use, distribution or copying of this information is strictly prohibited and may be unlawful.
If you have received this communication in error, please notify the sender immediately and destroy the original message and all attachments from your electronic files.

From: <wsbarp-bounces at lists.wsbarppt.com> on behalf of Sara Longley <sara at ivylawgroup.com>
Reply-To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Date: Wednesday, October 27, 2021 at 12:50 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Can a Will Revoke a JTWROS

Non-family lawyer here.

So, a spouse cannot *encumber* a CP asset without consent of the other spouse, but a spouse can *gift* their own ½ share of a CP asset via will.  Is that a good understanding?

Sara D. Longley
Senior Attorney
Ivy Law Group, PLLC
1734 NW Market Street
Seattle, WA 98107
Phone: (206) 706-2909
Fax: (206) 834-6044
sara at ivylawgroup.com<mailto:sara at ivylawgroup.com>
Pronouns: she, her, hers

[cid:image001.jpg at 01D7CB32.71140620]

From: wsbarp-bounces at lists.wsbarppt.com [mailto:wsbarp-bounces at lists.wsbarppt.com] On Behalf Of Roger Hawkes
Sent: Wednesday, October 27, 2021 12:28 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Can a Will Revoke a JTWROS

Thanks, Paul.  Interesting issues.  The statute impliedly recognizes that a married invidividual can gift his or her share of cp “by will” without the consent of the other.  Clearly a bequest is a ‘gift’; I believe the judges would find that section controls and allows gifting by will without the spouse or dpartner’s consent.

Roger Hawkes, WSBA # 5173
Sky Valley Law
For incoming mail: Box 351, Sultan 98294
For in person visits: 423 Main, Sultan, WA 98294
Or other places to be arranged
206 367 5000
360 799 6438
Fax: 206 367 4005

From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Paul Neumiller
Sent: Wednesday, October 27, 2021 12:16 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: Re: [WSBARP] Can a Will Revoke a JTWROS

This is my successful briefing from a 2003 case.  I have not revisited the issue since then.  I make no representations that it applies in this case, Just saying……….

ISSUE
            Whether the Gift Deed executed by the Decedent is a proper and valid gift of community real property without the signature or express or implied consent of her husband.
II.         RULE
            To be a proper and valid gift of community property, a spouse must have the express or implied consent of the other spouse.  To be a proper and valid conveyance of community real property, both spouses must join in the execution of the deed.
            Section 26.16.030 of the Revised Code of Washington, in part, states:
26.16.030. Community Property Defined – Management and Control. Property not acquired or owned, as prescribed in RCW 26.16.010 [Separate Property of Husband] and 26.16.020 [Separate Property of Wife], acquired after marriage by either husband or wife or both , is community property.  Either spouse, acting alone, may manage and control community property, with a like power of disposition as the acting spouse has over his or her separate property, except:…

(2)       Neither spouse shall give community property without the express or implied consent of the other.

(3)       Neither spouse shall sell, convey, or encumber the community real property without the other spouse joining in the execution of the deed or other instrument by which the real estate is sold, conveyed, or encumbered, and such deed or other instrument must be acknowledged by both spouses.….

In Nichols Hill Bank v. McCool, Jr., 104 Wn.2d 78, 701 P.2d 1114 (1985) (a copy of which is attached as Attachment “A”), the Washington Supreme Court interpreted RCW 26.16.030(2) where a husband guarantied a loan to a son without his wife’s consent.  The loan was discharged in bankruptcy for the son and the bank sought judgment against the husband’s separate property and the husband’s one-half interest in the community property. The trial court dismissed the claim against the husband’s community property.  The Supreme Court held that:

RCW 26.16.030(2) specifically requires the consent of both spouses before a gift of community property can be effectuated. If we found that a creditor could reach the donor spouse’s one-half interest in community property, the total amount of that property would be diminished. We would, in effect, be defying the statutory mandate by allowing the community estate to be gratuitously reduced without the consent of both spouses.

Id. at 88.  The Supreme Court affirmed the trial court judgment dismissing the claim against the husband’s community property solely because the wife had not given consent.
            A second case is factually similar to this matter. In Bosone v Bosone, 53 Wn. App. 614, 768 P.2d 1022 (1989) (a copy of which is attached as Attachment “B”), a husband and wife entered into a community property agreement that converted all of their separate assets into community property. Unbeknownst to the wife, the husband deeded their residence to his children from a former marriage.  After the husband’s death, his children from the former marriage listed the residence for sale and the surviving spouse brought a quiet title action. The Washington Court of Appeals affirmed the trial court’s grant of summary judgment to the wife and declared the deed void and invalid under both RCW 26.16.030(2) (requiring consent of both spouses for gift of community property) and RCW 26.16.030(3) (requiring both spouses to join in and acknowledge a conveyance of community real property.)

[cid:image002.jpg at 01D7CB32.71140620]

IMPORTANT NOTICE:  This e-mail message is intended to be received only by persons entitled to receive the confidential information it may contain. E-mail messages to clients of Paul A. Neumiller presumptively contain information that is confidential and legally privileged; e-mail messages to non-clients are normally confidential and may also be legally privileged. Please do not read, copy, forward or store this message unless you are the intended recipient of it. If you have received this message in error, please forward it back to the sender and delete it completely from your computer system.

E-mail communication on the Internet may NOT be secure. There is a risk that this confidential communication may be intercepted illegally. There may also be a risk of waiving attorney-client and/or work-product privileges that may attach to this communication. DO NOT forward this message to a third party. If you have any questions regarding this notice, please contact the sender.

From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Jeff at bellanddavispllc.com<mailto:Jeff at bellanddavispllc.com>
Sent: Wednesday, October 27, 2021 11:40 AM
To: 'WSBA Real Property Listserv' <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: Re: [WSBARP] Can a Will Revoke a JTWROS

But look at RCW 26.16.030(1):

  1.  Neither person shall devise or bequeath by will more than one-half of the community property.

How does this work with RCW 26.16.030(3) dealing with conveying community real property?  I still think you can, by Will, transfer the community interest to any person you want.  It just requires both parties, surviving spouse + heir(s) signing the deed.  This can lead to a partition action.

Jeff

W. Jeff Davis
BELL & DAVIS PLLC
P.O. Box 510
720 E. Washington Street, Suite 105
Sequim WA 98382
Phone: (360) 683.1129
Fax: (360) 683.1258
email: jeff at bellanddavispllc.com<mailto:jeff at bellanddavispllc.com>
www.bellanddavispllc.com<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.bellanddavispllc.com%2F&data=04%7C01%7C%7C8fc0f691d0b544496fb608d99979f3db%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C637709571350845734%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=ZO7FGVMnw5Co5J0bCYXczv3r6ajAj830Pq4sxhcIFus%3D&reserved=0>

The information contained in this e-mail message may be privileged, confidential, and protected from disclosure. If you are not the intended recipient, any dissemination, distribution, or copying is strictly prohibited. If you think that you have received this e-mail message in error, please e-mail the sender at info at bellanddavispllc.com<mailto:info at bellanddavispllc.com>  or call 360.683.1129.

From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Paul Neumiller
Sent: Wednesday, October 27, 2021 11:24 AM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: Re: [WSBARP] Can a Will Revoke a JTWROS

Plus, there is case law out there that says you must have the consent of both spouses to transfer community property.

[cid:image003.jpg at 01D7CB32.71140620]

From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Mark Anderson
Sent: Wednesday, October 27, 2021 11:16 AM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: Re: [WSBARP] Can a Will Revoke a JTWROS

After severing the joint tenancy in the case of a married/partnered couple, the property remains community property, however held. (See, RCW 64.28.040).

Mark B. Anderson
ANDERSON LAW FIRM PLLC
821 Dock St  Ste 209  PMB 4-12
Tacoma, Washington 98402
+1 253-327-1750
+1 253-327-1751 (fax)
marka at mbaesq.com<mailto:marka at mbaesq.com>
www.mbaesq.com<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.mbaesq.com%2F&data=04%7C01%7C%7C8fc0f691d0b544496fb608d99979f3db%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C637709571350855689%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=OQgNY0kB3TJcKS%2FHwd7pQR73GJCzNqmJVbizThmHgCA%3D&reserved=0>
CONFIDENTIALITY NOTICE
This transmission is confidential and is intended solely for the use of the individual named recipient. It may be protected by the attorney-client privilege, work product doctrine, or other confidentiality protection. If you are not the intended recipient, or the person responsible to deliver it to the intended recipient, be advised that any dissemination, distribution, or copying of this communication is prohibited. If you have received this transmission in error, please immediately notify the sender via e-mail or by telephone at (253) 327-1750 that you have received the message in error, and then delete it. Thank you.

From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of John J. Sullivan
Sent: Wednesday, October 27, 2021 9:09 AM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Cc: WSBA Probate & Trust Listserv <wsbapt at lists.wsbarppt.com<mailto:wsbapt at lists.wsbarppt.com>>
Subject: Re: [WSBARP] Can a Will Revoke a JTWROS

Jeff:

I would have the client deed his interest to himself as TIC, severing the JT.

https://www.santaellalaw.com/blog/2021/february/how-to-sever-joint-ownership-of-property/<https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.santaellalaw.com%2Fblog%2F2021%2Ffebruary%2Fhow-to-sever-joint-ownership-of-property%2F&data=04%7C01%7C%7C8fc0f691d0b544496fb608d99979f3db%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C637709571350865650%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=Q64zTjUXB1VFOtxCwC4o7o3RFy3ZOdOs%2F3xyX1IV3v8%3D&reserved=0>

I’m not a dirt attorney, but I would probably use a SWD rather than a QCD, to not risk losing title insurance.

One thing I’m not certain of, but I believe the effect is to convert the spouse’s interest into TIC as well.

John J. Sullivan
Sent from my iPhone

On Oct 27, 2021, at 8:48 AM, jeff at bellanddavispllc.com<mailto:jeff at bellanddavispllc.com> wrote:

John & Craig,

First, John,

I read RCW 64.28.010.  What does it mean that a joint tenant has a unilateral right to sever  the  joint tenancy.  How is that done?  Can the PC record a document saying he is severing the joint tenancy?

Craig,

I always understood that each spouse has a right to transfer their community interest, by Will, to anyone they want.  This become especially, painful, in a blended family setting where one spouse gives his or her CP interest to their children, without reserving a life estate in the surviving spouse.  Of course the step-children hate the evil step-parent and immediately move to sell the house to get their rightful share.

Jeff

W. Jeff Davis
BELL & DAVIS PLLC
P.O. Box 510
720 E. Washington Street, Suite 105
Sequim WA 98382
Phone: (360) 683.1129
Fax: (360) 683.1258
email: jeff at bellanddavispllc.com<mailto:jeff at bellanddavispllc.com>
www.bellanddavispllc.com<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.bellanddavispllc.com%2F&data=04%7C01%7C%7C8fc0f691d0b544496fb608d99979f3db%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C637709571350865650%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=ZcTKnej14sRYffsZ%2FQgCaofnaw3lQkn1kbHFJSbsb6o%3D&reserved=0>

The information contained in this e-mail message may be privileged, confidential, and protected from disclosure. If you are not the intended recipient, any dissemination, distribution, or copying is strictly prohibited. If you think that you have received this e-mail message in error, please e-mail the sender at info at bellanddavispllc.com<mailto:info at bellanddavispllc.com>  or call 360.683.1129.

From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Craig Blackmon
Sent: Wednesday, October 27, 2021 8:38 AM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Cc: WSBA Probate & Trust Listserv <wsbapt at lists.wsbarppt.com<mailto:wsbapt at lists.wsbarppt.com>>
Subject: Re: [WSBARP] Can a Will Revoke a JTWROS

I must ask: Isn't this actually community property? So don't you need that analysis as well, i.e. how to devise the client's 1/2 community interest in the property?

I love this list!

Craig
Craig Blackmon, Attorney at Law<https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.mywsba.org%2FPersonifyEbusiness%2FLegalDirectory%2FLegalProfile.aspx%3FUsr_ID%3D000000029240&data=04%7C01%7C%7C8fc0f691d0b544496fb608d99979f3db%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C637709571350875598%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=t2inYOxqVhxVlI97KraJ%2F75vaGwh5%2ByK57vxjCtQD6c%3D&reserved=0>
92 Lenora St. #8, Seattle WA  98121
Office/Cell: (206) 369-5949
On the blog: Co-Ownership of Real Property by Single People<https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.fsbolawyers.org%2Fblog%2Ftenants-in-common-agreement&data=04%7C01%7C%7C8fc0f691d0b544496fb608d99979f3db%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C637709571350875598%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=5MpW7oiiI7tVyKgdMrPGvHVhuMOZq15gbn4m%2BvLcRpI%3D&reserved=0>
[Image removed by sender.]<https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fseattlepropertylawyer.com%2F&data=04%7C01%7C%7C8fc0f691d0b544496fb608d99979f3db%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C637709571350885557%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=pHIypu97s%2BTFJrNSudz8341r5JX36VT9H3H5cFeySGs%3D&reserved=0>   [Image removed by sender.] <https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.fsbolawyers.org%2F&data=04%7C01%7C%7C8fc0f691d0b544496fb608d99979f3db%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C637709571350895515%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=VBk8y3bJmhzqmWQqku%2FVwBJq4%2BVmiJrLMbfdmb4Eaes%3D&reserved=0>
CONFIDENTIALITY NOTICE: This communication is a private, confidential electronic communication encompassed by 18 USC 2510. It is for the sole use of the intended recipient and receipt by anyone other than the intended recipient does not constitute a loss of its confidential or privileged nature.  Any review or distribution by others is strictly prohibited. If you are not the intended recipient please inform the sender and destroy all copies.

On Wed, Oct 27, 2021 at 8:31 AM John J. Sullivan <sullaw at comcast.net<mailto:sullaw at comcast.net>> wrote:
Jeff:

You are right that a super will provision will not achieve the client’s purpose.

But “ [a] joint tenancy shall have the incidents of survivorship and severability as at common law, including the unilateral right of each tenant to sever the joint tenancy ….”

https://app.leg.wa.gov/rcw/default.aspx?cite=64.28.010<https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fapp.leg.wa.gov%2Frcw%2Fdefault.aspx%3Fcite%3D64.28.010&data=04%7C01%7C%7C8fc0f691d0b544496fb608d99979f3db%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C637709571350895515%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=GNmgp0cm%2FDh4cQDtcJUdO3EPPF5JbWXQvFPXNEFp0iU%3D&reserved=0>

The client can sever the JTWROS if he wants his interest to pass under his will to his son.

John J. Sullivan

Sent from my iPad

On Oct 27, 2021, at 6:56 AM, Jeff at bellanddavispllc.com<mailto:Jeff at bellanddavispllc.com> wrote:

Listmates,

PC owns house with his wife as JTWROS.  He now wants to bequeath his ½ interest to his son.  This is a blended family and PC is afraid if he predeceases W, that W will leave everything to her children.  Can a Will, in essence a Super Will, defeat the Joint Tenancy?   In looking at RCW 11.11.010(7)(a)(i), it appears a JTWROS, like Transfer on Death Deeds, defeat any Will provision that tries to change those non-probate designations.  Have any of you had experience with this issue?

Jeff Davis

W. Jeff Davis
BELL & DAVIS PLLC
P.O. Box 510
720 E. Washington Street, Suite 105
Sequim WA 98382
Phone: (360) 683.1129
Fax: (360) 683.1258
email: jeff at bellanddavispllc.com<mailto:jeff at bellanddavispllc.com>
www.bellanddavispllc.com<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.bellanddavispllc.com%2F&data=04%7C01%7C%7C8fc0f691d0b544496fb608d99979f3db%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C637709571350905470%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=3RLF8mHKe9madgKcbSoXApXVPr2lSr8WJ%2FIp8OJhhuQ%3D&reserved=0>

The information contained in this e-mail message may be privileged, confidential, and protected from disclosure. If you are not the intended recipient, any dissemination, distribution, or copying is strictly prohibited. If you think that you have received this e-mail message in error, please e-mail the sender at info at bellanddavispllc.com<mailto:info at bellanddavispllc.com>  or call 360.683.1129.

***Disclaimer: Please note that RPPT listserv participation is not restricted to practicing attorneys and may include non-practicing attorneys, law students, professionals working in related fields, and others.***

_______________________________________________
WSBARP mailing list
WSBARP at lists.wsbarppt.com<mailto:WSBARP at lists.wsbarppt.com>
http://mailman.fsr.com/mailman/listinfo/wsbarp<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fmailman.fsr.com%2Fmailman%2Flistinfo%2Fwsbarp&data=04%7C01%7C%7C8fc0f691d0b544496fb608d99979f3db%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C637709571350915433%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=%2F81UFWVE5t2SFiTlx895utAuuYYx3HOLU90WJGTZT%2Fk%3D&reserved=0>
***Disclaimer: Please note that RPPT listserv participation is not restricted to practicing attorneys and may include non-practicing attorneys, law students, professionals working in related fields, and others.***

_______________________________________________
WSBARP mailing list
WSBARP at lists.wsbarppt.com<mailto:WSBARP at lists.wsbarppt.com>
http://mailman.fsr.com/mailman/listinfo/wsbarp<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fmailman.fsr.com%2Fmailman%2Flistinfo%2Fwsbarp&data=04%7C01%7C%7C8fc0f691d0b544496fb608d99979f3db%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C637709571350915433%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=%2F81UFWVE5t2SFiTlx895utAuuYYx3HOLU90WJGTZT%2Fk%3D&reserved=0>
***Disclaimer: Please note that RPPT listserv participation is not restricted to practicing attorneys and may include non-practicing attorneys, law students, professionals working in related fields, and others.***

_______________________________________________
WSBARP mailing list
WSBARP at lists.wsbarppt.com<mailto:WSBARP at lists.wsbarppt.com>
http://mailman.fsr.com/mailman/listinfo/wsbarp<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fmailman.fsr.com%2Fmailman%2Flistinfo%2Fwsbarp&data=04%7C01%7C%7C8fc0f691d0b544496fb608d99979f3db%7C84df9e7fe9f640afb435aaaaaaaaaaaa%7C1%7C0%7C637709571350925386%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=MUMta3CMA5R2MdmQmzWhU8R5ncwDKH%2Bn6kRvMmP7Y8Q%3D&reserved=0>
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mailman.fsr.com/pipermail/wsbarp/attachments/20211027/47e7df60/attachment.html>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image001.jpg
Type: image/jpeg
Size: 3153 bytes
Desc: image001.jpg
URL: <http://mailman.fsr.com/pipermail/wsbarp/attachments/20211027/47e7df60/image001.jpg>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image002.jpg
Type: image/jpeg
Size: 11295 bytes
Desc: image002.jpg
URL: <http://mailman.fsr.com/pipermail/wsbarp/attachments/20211027/47e7df60/image002.jpg>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image003.jpg
Type: image/jpeg
Size: 8031 bytes
Desc: image003.jpg
URL: <http://mailman.fsr.com/pipermail/wsbarp/attachments/20211027/47e7df60/image003.jpg>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image004.jpg
Type: image/jpeg
Size: 405 bytes
Desc: image004.jpg
URL: <http://mailman.fsr.com/pipermail/wsbarp/attachments/20211027/47e7df60/image004.jpg>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image005.jpg
Type: image/jpeg
Size: 441 bytes
Desc: image005.jpg
URL: <http://mailman.fsr.com/pipermail/wsbarp/attachments/20211027/47e7df60/image005.jpg>