Heather Benedict

453 S Spring Street

Ste 400 PMB1501
Los Angeles, CA 90013
E-mail: [email protected]

May 22, 2024

M Craig Bray
Managing Disciplinary Counsel - Intake
Office of Disciplinary Counsel
1325 4th Avenue, Suite 600
Seattle, WA 98101-2539
[email protected]

Re: Request for Review of Dismissal - ODC File: 24-00794

Dear Mr. Bray,

I am writing to formally request a review of the decision to dismiss my grievance against

attorney Kenyon Eldridge Luce, WSBA License Number 3081. I understand that my initial
complaint was dismissed under ELC 5.7(a) due to a lack of clear evidence of misconduct.
However, there are significant aspects of the case that merit further investigation and
reconsideration.

1. Improper Delegation and Misrepresentation:

On April 18, 2024, in the Pierce County Superior Court matter concerning the Estate of Leeanna
Ruth Mickelson (Case 16-4-00861-8), Mr. Luce sent his paralegal to a hearing for his motion
without proper authorization. The paralegal misrepresented the situation to the court by stating it
was my motion when it was actually Mr. Luce's. Mr. Luce did not appear or give proper notice,
citing a doctor's appointment, and failed to file the appropriate documentation indicating his
inability to attend. This delegation of responsibility to a nonlawyer assistant violates RPC 1.1
(Competence), RPC 1.4 (Communication), and RPC 5.3 (Responsibilities Regarding
Nonlawyer Assistants). The court reprimanded the paralegal, highlighting the seriousness of Mr.
Luce’s conduct. Given Mr. Luce’s advanced age (85 years old) and possible senility, this raises
significant ethical concerns about his ability to continue practicing law.

2. Reopening a Closed Matter:

Mr. Luce is attempting to reopen a probate case in Pierce County that was dismissed with
prejudice, a matter that has been closed for years. His client, who was the Personal
Representative with Letters of Administration in King County, managed the estate under Mr.
Luce's legal guidance, and the case was closed on December 20, 2020. This is a deliberate
attempt to stir the pot in a resolved matter in the wrong county. His actions could be seen as
harassment and an abuse of the legal process. The Washington Rules of Professional Conduct,
particularly RPC 3.1 (Meritorious Claims and Contentions) and RPC 3.2 (Expediting
Litigation), emphasize the importance of avoiding actions that unnecessarily delay or burden the
legal process. Mr. Luce's attempts to reopen this case clearly violate these principles.

3. Failure to Recognize Court Orders:

Mr. Luce failed to recognize his own order signed on October 13, 2017, which stated that no
motions could be heard without permission. Despite this, he recently asked the court to consider
a motion without obtaining the necessary permission. Although his request was denied, it has
taken a significant amount of my time to deal with this matter caused by Mr. Luce's apparent
senility and lack of attention to his previous orders.

4. Allegations of Senility and Fitness to Practice:

Given Mr. Luce’s age and the nature of his recent actions, there are serious concerns about his
character and fitness to continue practicing law. RPC 8.4 (Misconduct) includes provisions
against conduct involving dishonesty, fraud, deceit, or misrepresentation, as well as conduct
prejudicial to the administration of justice. The Character and Fitness Board should examine Mr.
Luce to determine if he is still fit to practice law, considering the allegations of senility and the
ethical breaches in his recent conduct.

5. Questionable Association with Christopher Constantine:

Mr. Luce's association with Christopher Constantine raises further concerns. Mr. Constantine’s
inconsistent use of “of Counsel Inc. P.S” and "OF COUNSEL INC, P.S." and his representation
as an associate of Luce & Associates, P.S., without clear employment status, could mislead the
court and parties about his professional affiliations. This association impacts Mr. Luce's
credibility and raises questions about the ethical standards of the Luce & Associates, P.S. Law
Firm, potentially violating RPC 7.1 (Communications Concerning a Lawyer's Services) and
RPC 7.5 (Firm Names and Letterheads).

Conclusion:
Given the above points, I respectfully request that the Office of Disciplinary Counsel re-examine
my grievance against Mr. Luce. The integrity of the legal process and the ethical standards of the
profession must be upheld. Additionally, I urge the Character and Fitness Board to evaluate Mr.
Luce's ability to continue practicing law, considering his advanced age and the recent incidents
that question his competence.

Thank you for your attention to this matter. I look forward to your prompt response.
Sincerely,

/s/ Heather Benedict

Office of Disciplinary Counsel
M Craig Bray
Managing Disciplinary Counsel ‐ Intake

May 24, 2024

Via email only

Kenyon Eldridge Luce

Luce & Associates, P.S.
5308 12th St E
Tacoma, WA 98424

Re: ODC File: 24‐00794

Grievance filed by Heather Benedict

Dear Kenyon Eldridge Luce:

We received the enclosed informa on dated May 22, 2024 from the grievant dispu ng the dismissal of
this grievance. Under Rule 5.7(b) of the Washington Supreme Court’s Rules for Enforcement of Lawyer
Conduct (ELC), we are referring this ma er to a Review Commi ee of the Disciplinary Board for its
considera on. In some situa ons, all of the informa on in a grievance file becomes public as a result of a
Review Commi ee’s decision. See ELC 3.1(b). The Review Commi ee will no fy you and the grievant
directly of its decision.

You may, but are not required to, respond to the grievant’s allega ons. Please submit any addi onal
informa on within two (2) weeks of the date of this le er. If you or the grievant submit addi onal
informa on and ask us to withhold any of it from the other, different procedures may apply. For more
informa on, see our website below.

h ps://www.wsba.org/for‐legal‐professionals/professional‐discipline/resources‐for‐lawyers

Sincerely,

M Craig Bray
Managing Disciplinary Counsel ‐ Intake

Enclosure: grievant informa on

cc: Heather Benedict (without enclosure)

DO NOT SEND ORIGINALS. We will scan and then destroy the documents you submit.

1325 4th Avenue | Suite 600 | Seattle, WA 98101‐2539

206‐727‐8207 | [email protected] | www.wsba.org
 Heather Benedict
453 S Spring Street
Ste 400 PMB1501
Los Angeles, CA 90013
E-mail: [email protected]

May 24, 2024

Managing Disciplinary Counsel - Intake

Office of Disciplinary Counsel
1325 4th Avenue, Suite 600
Seattle, WA 98101-2539
[email protected]

Re: Supplemental Complaint Against Kenyon Luce - Mismanagement of Trust Accounts and
Unauthorized Practice of Law - ODC File: 24-00794

I. Introduction

This supplemental complaint addresses additional concerns regarding the conduct of attorney
Kenyon Luce (Bar Number: 3081) in handling the estate of Cindy L. Kuchera (Pierce County
Superior Court Civil Case 16-4-00985-1). The issues raised pertain to the mismanagement of
trust accounts, unauthorized practice of law by a paralegal, Mr. Luce’s attempt to sell his law
firm under suspicious circumstances, and the use of an attorney not associated with his law firm
to obtain an order for estate closure. These actions suggest serious ethical and legal violations
that warrant further investigation and disciplinary action.

II. Detailed Allegations

1. Mismanagement of Trust Accounts:

Context: Mr. Luce held $570,094.43 in estate assets in his trust account. Virginia Syverson was
noted to receive $32,673.04, but a disclaimer of interest was filed on June 29, 2022, despite there
being no valid personal representative (PR) at the time. On July 29, 2022, Mr. Luce filed a
motion to appoint himself as the PR.

Misleading Actions: Virginia Syverson was misled by paralegal Sharon Rheinschild, who is not
an attorney, as indicated in the declarations filed on September 12, 2022. Mr. Luce’s response on
November 23, 2022, failed to adequately address these concerns.

Questionable Authorization: According to RCW 11.86.021, a disclaimer of interest must be

authorized by the beneficiary, their legal representative, or an authorized agent. There is no
indication that Virginia Syverson authorized Mr. Luce or anyone else to file this disclaimer on
her behalf. Additionally, the disclaimer was not notarized, raising questions about its authenticity
and verification.

ODC File: 24-00794 1

 No Recalculation of Distributions: Mr. Luce never attempted to recalculate the distribution
amount for Virginia Syverson to properly allocate her share to the other heirs. Instead, he noted
that none of the heirs would be impacted by the disclaimer. This indicates an attempt to keep the
funds for himself rather than distribute them appropriately among the heirs. He admitted that he
had no intention of distributing Virginia's funds properly.

Order Omitting Virginia: A court order dated September 27, 2022, omits Virginia Syverson
from the list of heirs, further indicating that Mr. Luce had no intention of properly handling her
share of the estate.

Improper Timing of Disclaimer: According to RCW 11.86.031, a disclaimer must be delivered

or mailed within nine months after the latest of specific dates. The estate was opened on June 3,
2016, making the disclaimer filed on June 29, 2022, untimely and invalid.

2. Attempted Sale of Law Firm:

Timing: Mr. Luce attempted to sell his law firm on July 7, 2022, shortly after the disclaimer of
interest was filed and before he was officially appointed as PR. This timing suggests an attempt
to dispose of the firm while holding estate funds.

Implications: This raises questions about whether Mr. Luce intended to distribute the estate
funds properly or if he sought to retain them improperly. Law Reference: According to RCW
9A.83.020, it is illegal to conduct or attempt to conduct a transaction involving the proceeds of
unlawful activity with the intent to conceal or disguise the nature, location, source, ownership, or
control of the proceeds. Mr. Luce’s actions in attempting to sell his law firm while managing
estate funds could be seen as an attempt to launder money.

3. Improper Use of Unassociated Attorney:

Incident: On November 30, 2022, Mr. Luce sent in Chris Constantine, who is not part of the
Luce law firm and did not file a notice of appearance or association, to obtain the order of estate
closure. This action is improper and further demonstrates the lack of transparency and adherence
to legal protocols.

III. Legal and Ethical Violations

1. Violation of Trust Account Regulations:

Misappropriation: Holding and potentially misappropriating estate funds without proper

authorization violates trust account regulations. This could be a violation of RPC 1.15A, which
governs the safekeeping of property.

Legal Duty: As the attorney for the deceased PR, Mr. Luce had a duty to promptly appoint a new
PR to ensure the proper management of the estate.

ODC File: 24-00794 2

 2. Unauthorized Practice of Law:

Paralegal’s Role: The interaction between Virginia Syverson and paralegal Sharon Rheinschild
constitutes unauthorized practice of law, which Mr. Luce failed to supervise properly. This is a
violation of RPC 5.3, which requires proper supervision of nonlawyer assistants.

3. Conflict of Interest:

Self-Appointment as PR: Mr. Luce's actions to appoint himself as PR while holding estate
funds raise concerns about conflict of interest and self-dealing, which may violate RPC 1.7
concerning conflict of interest.

4. Attempted Money Laundering:

Law Reference: According to RCW 9A.83.020, it is illegal to conduct or attempt to conduct a

transaction involving the proceeds of unlawful activity with the intent to conceal or disguise the
nature, location, source, ownership, or control of the proceeds. Mr. Luce’s actions in attempting
to sell his law firm while managing estate funds could be seen as an attempt to launder money.

5. Improper Use of Unassociated Attorney:

•
Violation: Sending in an attorney not associated with the law firm and who did not file a notice
of appearance or association to obtain the order of estate closure is a violation of court procedure
and ethical practice.

IV. Supporting Documentation

The following documents are attached to substantiate the claims made in this complaint:

1. Disclaimer of Interest by Virginia Syverson (E-filed June 29, 2022).

2. Copy of Kenyon Luce’s post to the WSBA Board in attempt to sell law firm quickly
(Posted July 7, 2022)
3. Affidavit of Kenyon Luce to be PR (E-filed July 29, 2022).
4. Declarations from September 12, 2022, concerning interactions with Virginia Syverson.
5. Response from Kenyon Luce to Virginia’s concerns (E-filed November 23, 2022).

V. Authorities

1. Washington Rules of Professional Conduct (RPC 1.15A): Obligations regarding

safekeeping property and managing client trust accounts.
2. RPC 5.3: Responsibilities regarding nonlawyer assistants to prevent unauthorized
practice of law.
3. RPC 1.7: Governs conflict of interest and addresses self-dealing concerns.
4. RCW 9A.83.020: Governs the prohibition of money laundering and related transactions.
5. RCW 11.86.021: Details requirements for disclaiming an interest in an estate.

ODC File: 24-00794 3

 6. RCW 11.86.031: Specifies the contents, timing, and filing requirements for disclaimers of
interest.

VI. Conclusion

The actions of Kenyon Luce in this matter suggest serious ethical and legal violations that
warrant further investigation and disciplinary action. His mismanagement of trust accounts,
unauthorized practice of law by a paralegal, the timing of his attempt to sell his law firm, and
potential money laundering are particularly concerning.

I respectfully request that the Washington State Bar Association thoroughly investigate these
matters to ensure the integrity of the legal profession and protect the interests of the estate and its
beneficiaries.

Sincerely,

/s/ Heather Benedict

ODC File: 24-00794 4

 E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON

June 29 2022 10:00 AM

CONSTANCE R. WHITE
COUNTY CLERK
NO: 16-4-00985-1

ODC File: 24-00794 5

ODC File: 24-00794 6
ODC File: 24-00794 7
 7/14/22, 9:11 PM [WSBAPT] Firm for sale to attorney who will assume with others in the firm it's continuation. Ownership is possible a case load exi…

[WSBAPT] Firm for sale to attorney who will

assume with others in the firm it's continuation.
Ownership is possible a case load existing would be
helpful open contact me period.
Ken Luce Ken.Luce at lucelawfirm.com
Thu Jul 7 08:00:42 PDT 2022

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mailman.fsr.com/pipermail/wsbapt/2022-July/022648.html 1/1 8
 E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON

July 29 2022 12:39 PM

CONSTANCE R. WHITE
COUNTY CLERK
NO: 16-4-00985-1

ODC File: 24-00794 9

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 E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON

September 12 2022 1:55 PM

CONSTANCE R. WHITE
COUNTY CLERK
NO: 16-4-00985-1

ODC File: 24-00794 16

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 E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON

September 12 2022 1:55 PM

CONSTANCE R. WHITE
COUNTY CLERK
NO: 16-4-00985-1

ODC File: 24-00794 23

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 E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON

October 20 2022 2:21 PM

CONSTANCE R. WHITE
COUNTY CLERK
NO: 16-4-00985-1

ODC File: 24-00794 30

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 E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON

October 17 2022 8:30 AM

CONSTANCE R. WHITE
COUNTY CLERK
NO: 16-4-00985-1

SUPERIOR COURT OF WASHINGTON

FOR PIERCE COUNTY

Estate of
NO. 16-4-00985-1

Cindy L. Kuchera, REQUEST FOR INVENTORY &

ACCOUNTING

Deceased. RCW 11.44.015(2)

This action commenced more than 90 days and the undersigned is pro se and heir at
law to the Estate of Cindy L. Kuchera. Now therefore, it is hereby requested the Personal
Representative furnish to me, within ten (10) days of receipt herein, a copy of the estate
inventory, appraisement, trust ledger, all receipts, accounting records from DP&C, and
final report and also file in the court, RCW 11.76.030.

Dated: August 8, 2022

Signature: /s/ Virginia Syverson

Virginia Syverson

675 Seacoast Drive

Imperial Beach, CA 91932
[email protected]
(619) 341-2656

Request for Inventory and Accounting Virginia Syverson

Declaration of Mailing 675 Seacoast Drive
RCW 11.44.015(2) Imperial Beach, CA 91932
Page 1 of 2 (619) 341-2656
ODC File: 24-00794 36
 DECLARATION OF MAILING

In accordance with RCW 9A.72.085, I declare under penalty of perjury under the laws
of the State of Washington that on the date written below, I mailed by first-class mail of
the US Postal Service, postage prepaid, a true and correct copy of this

Request for Special Notice &

Declaration of Mailing

To: The Deceased Personal Representative, Stacy Columbel, through Her Attorney,
addressed as follows:

Kenyon Luce, Attorney

5308 12th St. E
Tacoma, WA 98424-2796

And to: The Accounting Firm who billed the estate $1,815.00 on July 27, 2022,
addressed as follows:

Jason Kors, CPA, MS Tax

DP&C
P.O. Box 1614
Tacoma, WA 98401-1614

SIGNED

Date: On August 8, 2022

Place: At Imperial Beach, California

Signature: /s/ Virginia Syverson

Request for Inventory and Accounting Virginia Syverson

Declaration of Mailing 675 Seacoast Drive
RCW 11.44.015(2) Imperial Beach, CA 91932
Page 2 of 2 (619) 341-2656
ODC File: 24-00794 37
 E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON

October 20 2022 2:21 PM

CONSTANCE R. WHITE
COUNTY CLERK
NO: 16-4-00985-1

ODC File: 24-00794 38

ODC File: 24-00794 39
ODC File: 24-00794 40
ODC File: 24-00794 41
ODC File: 24-00794 42
ODC File: 24-00794 43
 E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON

October 26 2022 10:50 AM

CONSTANCE R. WHITE
COUNTY CLERK
NO: 16-4-00985-1

ODC File: 24-00794 44

 E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON

October 26 2022 8:30 AM

CONSTANCE R. WHITE
COUNTY CLERK
NO: 16-4-00985-1

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON

IN AND FOR THE COUNTY OF PIERCE

In the Matter of the Estate of: NO. 16-4-00985-1

Cindy L. Kuchera, RESPONSE TO PR’S MOTION TO

DISBURSE FUNDS AND OBJECTION TO
Deceased. CLOSE THE ESTATE WITHOUT
FURTHER ACCOUNTING

I. INTRODUCTION

This Court has yet to determine heirship beyond one first cousin, and there remains

$98,228 unaccounted for by Luce & Associates that needs to be addressed first before the

probate can be closed.

II. FACTS AND LEGAL AUTHORITY

In this motion to disburse funds and close probate, the personal representative Kenyon

Luce submitted totals that is not supported by billing statements. Mr. Luce’s expense total is

$98,228, but no paper trail exists.

Who are the legal heirs at law? A June 6, 2016 court order rules there is only one, now

Mr. Luce says there are 21, including myself. The court should clarify the heirs, RCW 11.28.340.

On December 16, 2016, the then-personal representative filed a declaration that she

believed the probate fees would not exceed $15,000, so a bond was issued for this amount.

However, on June 11, 2019, Mr. Luce stated that attorney fees for $26,000, which exceeds the

bond, were approved by the now-deceased personal representative, RCW 5.60.030.

On June 3, 2022, Mr. Luce advised the court that the original personal representative was

now deceased, and it is still unclear who the new personal representative is. The record is void of

ODC File: 24-00794 45

 letters testamentary, RCW 11.28.090 and Mr. Luce has not filed an oath to serve as the personal

representative. The court has not yet recognized the surrender of the deceased personal

representative, RCW 11.28.280.

This estate’s cash does not appear to be part of the estate assets any longer, and it is

unknown where it went. The final accounting, filed on October 20, 2022, is unclear where the

$58,180 in cash from Decedent’s Home went from July 7, 2016, and the bank account outside of

the trust deposited $58,777 on July 20, 2016. To that end, there are no receipts yet in the record

from anyone who has supposedly received their disbursement already.

On October 17, 2022, I filed a Request for Inventory and Accounting RCW 11.44.015,

and Mr. Luce’s accounting was void of any attorney billing records. If indeed the CPA firm

DP&C was hired, their accounting statements should be readily available, but they are not.

Further, the actual appraisement of the coin collection was not provided, and it is still being

determined where the personal photo album will go. I would be interested in the album.

On the top of page three, section four, is my spreadsheet of the final accounting and is

according to Mr. Luce’s motion, which shows the $98,228 in unaccounted expenses to the estate.

III. CONCLUSION

In conclusion, I am curious what is going on with the $98,228 in expenses, particularly

the $58,777 that disappeared from the trust bank account on July 20, 2016 and believe

everything else adds up correctly.

Signed this 25th day of October 2022 in Imperial Beach, California.

/s /Virginia Syverson
VIRGINIA SYVERSON
675 Seacoast Drive
Imperial Beach, CA 91932
[email protected]
(619) 341-2656

ODC File: 24-00794 46

 IV. ACCOUNTING OF ESTATE OF CINDY L. KUCHERA, as of October 20, 2022

ODC File: 24-00794 47

 V. CERTIFICATE OF SERVICE

The undersigned solemnly affirms that on 25th day of October 2022, the undersigned

electronically served a copy of the RESPONSE TO PR’S MOTION TO DISBURSE FUNDS

AND OBJECTION TO CLOSE THE ESTATE WITHOUT FURTHER ACCOUNTING to

Kenyon Luce of Luce & Associates Law Firm.

I declare under penalty of perjury under the laws of the State of Washington that the

foregoing is true and correct.

/s/Virginia Syverson
VIRGINIA SYVERSON

ODC File: 24-00794 48

 E-FILED
IN COUNTY CLERK'S OFFICE
PIERCE COUNTY, WASHINGTON

November 30 2022 2:42 PM

CONSTANCE R. WHITE
COUNTY CLERK

IN THE SUPERIOR COURT, PIERCE COUNTY, WASHINGTON

ESTATE OF CINDY L KUCHERA Cause Number: 16-4-00985-1

Memorandum of Journal Entry
vs

Judge/Commissioner: DORIS WALKINS

Court Reporter: JAVS
Judicial Assistant: Danielle Frazier
COLOMBEL, STACY A KENYON ELDRIDGE LUCE Attorney for Involved Party
KUCHERA, CINDY L.
LUCE, KENYON E
KEMP & ASSOCIATES Rebecca Kaye Reeder Attorney
ASAY, MARSHA Carolyn W. Miller Attorney for Involved Party
LIVENGOOD, LINDA Carolyn W. Miller Attorney for Involved Party
PAYNE, MICHAEL TRAVIS
SPEIDEL, SHANEA Carolyn W. Miller Attorney for Involved Party
KORICH, DENISE L Carolyn W. Miller Attorney for Involved Party
KORICH, MICHAEL Carolyn W. Miller Attorney for Involved Party
KORICH, MARCIA C Carolyn W. Miller Attorney for Involved Party
KORICH, SHANE
RENTERIA, KAREN D Carolyn W. Miller Attorney for Involved Party
KORICH, RUSSELL J Carolyn W. Miller Attorney for Involved Party
COLOMBEL, ANTHONY CRAIG Nancy L Sorensen Attorney for Involved Party
COLOMBEL, CRAIG Nancy L Sorensen Attorney for Involved Party

Proceeding Set: Guardianship/Probate Proceeding Date: Nov 30, 2022 1:49 PM

Proceeding Outcome: Held - Motion
Resolution:

Clerk's Code: MTHRG

Proceeding Outcome code: MTHRG
Resolution Outcome code:
Amended Resolucton code:

Memornadum of Journal Entry.

ODC File: 24-00794 49
Page1 of 2
 16-4-00985-1

IN THE SUPERIOR COURT, PIERCE COUNTY, WASHINGTON

ESTATE OF CINDY L KUCHERA Cause Number: 16-4-00985-1

vs Memorandum of Journal Entry

Judge/Commissioner: DORIS WALKINS

MINUTES OF PROCEEDING

Start Date/Time: Nov 30, 2022 1:32 PM Judicial Assistant: Danielle Frazier
Court Reporter: JAVS

November 30, 2022 01:34 PM -

Court calls case, no party appears. Court will recall case.

01:45 PM - back on the record. Attorney Chris Constantine present via zoom. No other party
present.

Court directs Mr. Constantine to submit directly to the court the proof of service to be emailed
in .

Once the court receives the email, the court will sign off on the order.

02:41 PM - Court receives, reviews and accepts proof of service.

Court signs off on order for distrubtion.

End Date/Time: Nov 30, 2022 1:49 PM

Memornadum of Journal Entry.

ODC File: 24-00794 50
Page2 of 2
 Heather Benedict
453 S Spring Street
Ste 400 PMB1501
Los Angeles, CA 90013
E-mail: [email protected]

May 24, 2024

Managing Disciplinary Counsel - Intake

Office of Disciplinary Counsel
1325 4th Avenue, Suite 600
Seattle, WA 98101-2539
[email protected]

Re: Second Supplemental Complaint Against Kenyon Luce - Improper Disbursement of Estate
Funds - ODC File: 24-00794

I. Introduction

This second supplemental complaint addresses additional concerns regarding the conduct of
attorney Kenyon Luce (Bar Number: 3081) in handling the estate of Cindy L. Kuchera (Pierce
County Superior Court Civil Case 16-4-00985-1). Specifically, this complaint focuses on the
improper disbursement of estate funds to Mr. Luce’s law firm, Luce & Associates, rather than to
the rightful heir. These actions suggest serious ethical and legal violations that warrant further
investigation and disciplinary action.

II. Detailed Allegations

Improper Disbursement of Estate Funds:

Context: On August 17, 2023, an order was approved and electronically signed by Pierce
County Commissioner Craig S. Adams, authorizing the disbursement of estate funds back to
Luce & Associates. This order is unusual and raises questions about the proper management and
distribution of estate funds.

Lack of Evidence of Distribution to Heir: There is no evidence that Mr. Luce disbursed the
funds to the rightful heir, Virginia Syverson. Instead, the funds were directed back to his law
firm, which raises concerns about potential misappropriation or mishandling of estate assets.
Violation of Trust Account Regulations: There is no paper trail indicating that the money was
properly transferred to the clerk's office or subsequently to the heir at law.

RPC 1.15A (Safekeeping Property): This rule requires that lawyers hold property of clients or
third persons that is in a lawyer’s possession in connection with a representation separate from
the lawyer’s own property. By directing estate funds to his law firm without proper justification,
Mr. Luce may have violated this rule.

ODC File: 24-00794 51

 RPC 1.15A (Client Trust Account): Funds belonging to a client or third party must be
deposited into a client trust account. The disbursement of estate funds to Mr. Luce’s law firm,
rather than maintaining them in a trust account for the rightful heir, suggests a breach of this
duty.

Conflict of Interest:

RPC 1.7 (Conflict of Interest: Current Clients): Mr. Luce’s actions in directing estate funds to
his law firm, rather than disbursing them to the heir, indicate a potential conflict of interest. His
personal financial interest in receiving the funds conflicts with his duty to distribute the estate
assets according to the law and the decedent’s wishes.

III. Legal and Ethical Violations

Misappropriation: Holding and potentially misappropriating estate funds without proper

authorization violates trust account regulations (RPC 1.15A).
Conflict of Interest: Directing funds to his law firm rather than distributing them to the heir raises
concerns about conflict of interest and self-dealing (RPC 1.7).

IV. Supporting Documentation

The following documents are attached to substantiate the claims made in this complaint:

1. Order to Disburse Funds to Luce & Associates (E-filed August 17, 2023).

V. Conclusion

The actions of Kenyon Luce in directing estate funds to his law firm without proper
disbursement to the rightful heir suggest serious ethical and legal violations. These issues
warrant further investigation and disciplinary action to ensure the integrity of the legal profession
and protect the interests of the estate and its beneficiaries.

I respectfully request that the Washington State Bar Association thoroughly investigate these
matters.

Sincerely,

/s/ Heather Benedict

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 E-FILED
IN OPEN COURT
Exparte Mail
Order approved and electronically signed August 17 2023 3:59 PM
August 17 2023 3:59 PM

Pierce County Clerk

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Case: ESTATE OF CINDY L KUCHERA
Cause Number: 16-4-00985-1
Filing ID: 58434019
Signed: August 17 2023 03:59 PM

This order has been reviewed, approved, and electronically signed.

Craig S Adams, Pierce County Commissioners

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 Accountability Audit Report

Pierce County
For the period January 1, 2022 through December 31, 2022

Published March 4, 2024 Scan to see another great way

we’re helping advance
Report No. 1034366 #GoodGovernment

ODC File No. 24-00794 62

 Office of the Washington State Auditor
Pat McCarthy
March 4, 2024

County Executive and Council

Pierce County
Tacoma, Washington

Report on Accountability
The Office of the Washington State Auditor takes seriously our role of providing state and local
governments with assurance and accountability as the independent auditor of public accounts. In
this way, we strive to help government work better, cost less, deliver higher value and earn greater
public trust.

Independent audits provide essential accountability and transparency for County operations. This
information is valuable to management, the governing body and public stakeholders when
assessing the government’s stewardship of public resources. Audits also promote accountability
and openness in government.

Attached is our independent audit report on the County’s compliance with applicable requirements
and safeguarding of public resources for the areas we examined. We think your staff and the public
will find value in this work.

Sincerely,

Pat McCarthy, State Auditor

Olympia, WA

Americans with Disabilities

In accordance with the Americans with Disabilities Act, we will make this document available in
alternative formats. For more information, please contact our Office at (564) 999-0950, TDD
Relay at (800) 833-6388, or email our webmaster at [email protected].

Insurance Building, P.O. Box 40021  Olympia, Washington 98504-0021  (564) 999-0950  [email protected]

ODC File No. 24-00794 63

 TABLE OF CONTENTS
Audit Results................................................................................................................................... 4

Schedule of Audit Findings and Responses .................................................................................... 6

Related Reports ............................................................................................................................. 12

Information about the County ....................................................................................................... 13

About the State Auditor's Office ................................................................................................... 14

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 AUDIT RESULTS
Results in brief
This report describes the overall results and conclusions for the areas we examined. In most of the
areas we examined, County operations complied, in all material respects, with applicable state
laws, regulations, and its own policies, and provided adequate controls over safeguarding of public
resources.

As referenced above, we identified areas where the County could make improvements. These
recommendations are included with our report as a finding.

In keeping with general auditing practices, we do not examine every transaction, activity, policy,
internal control, or area. As a result, no information is provided on the areas that were not
examined.

About the audit

This report contains the results of our independent accountability audit of Pierce County from
January 1, 2022 through December 31, 2022.

Management is responsible for ensuring compliance and adequate safeguarding of public resources
from fraud, loss or abuse. This includes the design, implementation and maintenance of internal
controls relevant to these objectives.

This audit was conducted under the authority of RCW 43.09.260, which requires the Office of the
Washington State Auditor to examine the financial affairs of all local governments. Our audit
involved obtaining evidence about the County’s use of public resources, compliance with state
laws and regulations and its own policies and procedures, and internal controls over such matters.
The procedures performed were based on our assessment of risks in the areas we examined.

Based on our risk assessment for the year ended December 31, 2022, the areas examined were
those representing the highest risk of fraud, loss, abuse, or noncompliance. We examined the
following areas during this audit period:

• Office of the Clerk of the Superior Court – trust fund account activity, cash receipting,
bank reconciliations, timeliness and completeness of deposits, voids and adjustments,
daily and monthly audit report reviews and unclaimed property reporting
• Use of restricted funds – park impact fees
• Planning and Public Works Department – conflict of interest and building permits
• Accounts payable – electronic funds transfers
• Accounts receivable – sewer utility billing

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 • Self-insurance for property and liability and workers’ compensation
• Financial condition – reviewing for indications of financial distress
• Open public meetings – compliance with minutes, meetings and executive session
requirements

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 SCHEDULE OF AUDIT FINDINGS AND RESPONSES

Pierce County
January 1, 2022 through December 31, 2022

2022-001 The Clerk’s Office does not have sufficient oversight or internal
controls over its financial operations to safeguard public resources.

Background
The Office of the Clerk of the Superior Court (Clerk’s Office) collected
$14.8 million in revenue for fines, fees and restitution payments in 2022. The Clerk
is responsible for developing policies and ensuring the office has adequate and
effective controls in place over its operations. Our audit found the Clerk’s Office
lacks important controls over its accounting operations. Without these controls, the
Clerk’s Office cannot ensure it safeguards funds and increases its risk of
misappropriation, loss of public assets, and noncompliance.
One of the Clerk’s Office’s duties is to collect and hold monies in trust for
restitution, such as settlement payments, funds held until a minor’s 18th birthday,
and partially resolved divorce proceedings. The Clerk’s Office is supposed to
deposit these funds into separate bank accounts held on behalf of litigants or
beneficiaries until the court-ordered maturity date.

Description of Condition
Our audit found the Clerk’s Office had insufficient oversight and control
deficiencies over its trust fund accounts and reconciliations, bank reconciliations
and non-cash adjustments, Judicial Information System audit reports, and
unclaimed property reports.

Trust fund accounts and reconciliations

We identified the following control deficiencies regarding the creation of trust fund
accounts and the monthly bank account reconciliation process. The Clerk’s Office:

• Has not created a trust fund account for one check totaling $251,676. The
check has a court order that was signed and filed on August 10, 2023,
instructing the Clerk’s Office to invest the funds into a trust account.
However, as of January 2024, the paper check was still in the Clerk’s
Office’s vault.

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 • Does not reconcile trust fund account balances to monthly bank statements.
Instead, each account shows a balance as of the last period when the bank
reported activity to the Clerk’s Office. As of January 8, 2024, the average
trust account was last reconciled to bank statements more than two years
ago.
• Has not disbursed funds to beneficiaries once a trust account has matured.
We tested all 46 individual trust bank accounts held by the Clerk’s Office.
We determined 11 accounts have matured, but the Clerk’s Office has not
disbursed any of the funds. Those 11 trust fund accounts represent
$1.89 million, or 93 percent of the total trust account bank balances. Further,
we determined eight of the 11 trust accounts have not had bank activity
since 2021. The remaining three accounts have not had bank activity since
July 2023. Our audit determined that staff and management are unaware of
the Clerk’s Office’s responsibilities for safeguarding and disbursing these
funds once the trust fund accounts have matured.

Bank reconciliations and non-cash adjustments

We identified insufficient oversight and the following control deficiencies over

bank reconciliations, accounts receivables and adjustments. The Clerk’s Office:

• Does not perform monthly bank balance reconciliations. The Clerk’s Office
has procedures that require staff to reconcile daily deposits and checks, but
no one reviews the reconciliations to ensure they are performed timely and
accurately. As a result, the bank balance reported in the Clerk’s Office’s
financial system, Judicial Information System (JIS), was $2,470,074 less
than the bank statement balance as of January 2, 2024.
• Does not have an independent review and approval process for new
receivables, receipts for voids or batch exceptions, and support for other
receivables adjustments. An independent review and approval process is
necessary for ensuring staff have correctly established and adjusted
receivables.
• Has not recorded adjustments in a timely manner. We reviewed 24 negative
receivables adjustments, and determined two cases were not recorded until
31 and 24 days after the court orders were filed.

JIS audit reports

JIS is a court software and information system managed by the Washington State
Administrative Office of the Courts under the direction of the chief justice of the

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 state Supreme Court. The Clerk’s Office must comply with the timelines for
scheduling and retaining records that are established in the JIS Online Manuals.
The manuals identify reports that are essential for internal controls and compliance,
as well as the frequency with which the Clerk’s Office should print them. We
reviewed the Clerk’s Office’s monthly and daily JIS audit reports, and identified
the following control deficiencies:

• Forty-three of 60 monthly audit reports were printed, but the Clerk’s Office
did not have evidence showing that staff reviewed them. The Clerk’s Office
did not retain the other 17 reports, so we were unable to determine whether
staff printed and reviewed them.
• Fifty-nine of 75 daily audit reports were printed, but the Clerk’s Office did
not have evidence showing that staff reviewed them. The Clerk’s Office did
not retain the other 16 reports, so we were unable to determine whether staff
printed and reviewed them.

Unclaimed property report

The Washington State Department of Revenue requires governmental entities to

annually report unclaimed property by October 31. The Clerk’s Office did not
ensure it filed the 2023 unclaimed property report by the required deadline. Instead,
the Clerk’s Office filed the report on December 12, 2023, which was 42 days after
the due date. Further, the Clerk’s Office did not request a filing extension until
November 9, 2023. The Department of Revenue notified the Clerk’s Office that it
must request an extension before the filing deadline. Our audit determined the
Clerk’s Office’s 2023 unclaimed property report did not include any matured trust
fund monies since staff and management do not know whether unclaimed property
laws apply to these trust fund accounts.

Cause of Condition
A new Clerk was appointed in December 2021. In June 2023, the Clerk’s Office
experienced multiple vacancies in key financial positions. The combined effect of
turnover and staffing shortages has resulted in the loss of institutional knowledge,
including the responsibilities the Clerk’s Office may have for the disposition of
matured trust fund accounts. The turnover and staffing shortages have also caused
a significant backlog of transactions that the Clerk’s Office has yet to process,
including electronic receipts that have been deposited in the bank but not yet
recorded in JIS. The Clerk’s Office lacked adequate staffing to process these
transactions timely while it tried to hire new staff for its key financial positions.

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 Effect of Condition
Insufficient oversight and inadequate internal controls increase the Clerk’s Office’s
risk of experiencing and not detecting a loss or misappropriation of public funds.
In addition, by continuing to hold $1.89 million in trust fund accounts beyond the
court-ordered maturity dates, the Clerk’s Office deprives beneficiaries of receiving
money to which they may be entitled.
Lastly, late report filings for unclaimed property with the Department of Revenue
can result in the County paying significant late fees. It also increases the risk that
people with matured trust fund accounts or other unclaimed property will be unable
to claim their assets from the Clerk’s Office.

Recommendation
We recommend the Clerk implement appropriate oversight and strengthen internal
controls over trust fund accounts and reconciliations, bank reconciliations and non-
cash adjustments, JIS audit reports, and unclaimed property reports. Specifically,
the Clerk should:

• Establish trust fund accounts on behalf of beneficiaries in a timely manner

and according to court orders
• Reconcile, review, approve and document monthly reconciliations of trust
fund account balances to ensure activity is accurately recorded and
adequately supported
• Evaluate matured trust fund accounts to determine the appropriate
disposition of these funds, including whether any of the funds should be
reported and remitted as unclaimed property to the Department of Revenue
• Reconcile, review, approve and document monthly reconciliations of the
Clerk’s Office’s bank account balances to ensure activity is accurately
recorded and adequately supported
• Review, approve and document the review of new receivables created by
accounting staff to ensure they are valid, set up correctly and adequately
supported
• Review, approve and document the review of voids, batch exceptions, and
other receivables adjustments recorded by accounting staff to ensure they
are valid, timely and accurate
• Submit the annual unclaimed property report by the required due date
established by the Department of Revenue. If the Clerk’s Office cannot file
a report by the deadline, it should request an extension from the Department
of Revenue before the filing deadline.

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 County’s Response
While there was no loss of or misuse of funds identified in this audit, it did raise
concerns that the internal processes and reporting timeliness of the Superior Court
Clerk’s Office do not meet accounting standards. We were aware of those
performance gaps and have been implementing an improvement plan for several
months.

The Clerk’s Office and the County’s Finance department have been working
collaboratively to improve internal processes and speed reporting. Hiring for key
staff roles has helped accelerate the pace of improvement in these areas.

Enhanced training is also helping with reducing backlogs and meeting the
reporting requirements of the state’s Administrative Office of the Courts

Pierce County thanks the State Auditor’s Office for its attention to the proper and
timely handling of public funds.

Auditor’s Remarks
The County has the fiduciary responsibility to ensure proper oversight and internal
controls are in place to safeguard public funds to prevent their loss or misuse. Our
audit identified a significant lack of oversight and internal controls in the financial
operations of the Clerk’s Office to prevent or detect the loss of public funds.
The County’s improvement plan or steps taken to address the identified concerns
were not shared or provided for consideration at any time during the audit process.
We re-affirm the finding and will review the County’s corrective action during our
next audit.

Applicable Laws and Regulations

RCW 43.09.240, Local government accounting—Public officers and employees—
Duty to account and report—Removal from office—Deposit of collections, states
in part that “every public officer and employee, whose duty it is to collect or receive
payments due or for the use of the public shall deposit such moneys collected or
received by him or her with the treasurer of the local government once every
twenty-four consecutive hours. Exceptions granted by the treasurer shall state the
frequency with which deposits are required as long as no exception exceeds a time
period greater than one deposit per week.”

RCW 36.48.090, Clerk’s trust fund created—Deposits—Interest—Investments,

requires that the clerk of the superior court to deposit funds held in trust for any

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 litigant or any purpose in a separate fund designated “clerk’s trust fund,” and these
funds shall not be commingled with any public funds.

The Budgeting, Accounting and Reporting System (BARS Manual), 3.2.4, Money
Held in Trust, requires “the clerk of the superior court to deposit moneys held in
trust for any litigant or for any purpose in a separate bank account designated Court
Trust Fund pursuant to RCW 36.48.090.” It also requires that “clerks making trust
fund investments must maintain an investment ledger and reconcile the ledger to
bank and investment account statements and the county general ledger on a monthly
basis.”

BARS Manual, 3.1.9, Bank Reconciliations, requires governments to “document a

global bank reconciliation that includes reconciliation of both the ending balance
of cash as well as cash activity at least monthly . . . Governments should consider
more frequent reconciliations, such as daily reconciliations for accounts with a
large amount of activity or that are at higher risk for fraud or invalid payments, such
as the main checking account for a larger government . . . [The State Auditor’s
Office] does not prescribe how governments might organize their bank accounts or
the corresponding accounting records. However, the number and type of accounts,
banking practices, organization of accounting records, and the methods, division
and stages of reconciliation established by the government should not represent a
barrier to effective control.”

BARS Manual, 3.1.3, Internal Control, states that “a government’s management

and governing body are responsible for its performance, compliance and financial
reporting. Therefore, the adequacy of internal controls to provide reasonable
assurance in achieving these objectives is also the responsibility of management,
with oversight from the governing body. Since internal control is as fundamental
as the objectives the controls relate to, the need for effective control is applicable
to all organizations.”

The JIS Online Manuals, Scheduling and Retention of Records, identifies JIS and
JRS reports applicable for superior courts, the frequency with which they should be
printed, and whether they are designated as part of the “audit trail,” which indicates
they are essential for operational control, accounting control, audit, and compliance
with government regulations. The authority for records retention and disposition is
RCW 40.14.070 & WAC 434-635-050.

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 RELATED REPORTS
Financial
Our opinion on the County’s financial statements and compliance with federal grant program
requirements is provided in a separate report, which includes the County’s financial statements.
That report is available on our website, http://portal.sao.wa.gov/ReportSearch.

Federal grant programs

We evaluated internal controls and tested compliance with the federal program requirements, as
applicable, for the County’s major federal programs, which are listed in the Schedule of Findings
and Questioned Costs section of the separate financial statement and single audit report. That
report includes federal findings regarding internal controls and noncompliance with reporting,
matching, and subrecipient monitoring requirements. That report is available on our website,
http://portal.sao.wa.gov/ReportSearch.

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 INFORMATION ABOUT THE COUNTY
Pierce County was incorporated in 1852 and operates under a Home Rule Charter adopted by
voters in 1980. The County is organized under the executive-council form of government. Elected
administrative officials include the County Executive (Chief Executive Officer), Prosecuting
Attorney, Assessor-Treasurer, Auditor, Sheriff, Superior Court Judges and District Court Judges.
The seven-member County Council is elected by district and is the policy-setting body of the
County.

For 2022-2023, the County operated on a biennial budget of $3 billion. The County’s 3,367
employees provide services including public safety, fire inspection, road construction and
maintenance (including ferry service from Steilacoom to Ketron and Anderson Islands), flood
control, parks and recreation, judicial administration, land-use planning and development, health
and social services, sewer utility services and certain solid waste programs.

The County is the second most populated county in the state with 937,400 residents. The County
is responsible for appointing board members to various boards including: Pierce County Housing
Authority, Community Development Corporation, and the Economic Development Corporation.
Additionally, the County has a joint venture with the Tacoma-Pierce County Health Department.

Contact information related to this report

Pierce County
Address: 950 Fawcett Avenue, Suite 100
Tacoma, WA 98402

Contact: Thomas Taylor, Internal Auditor

Telephone: (253) 798-7577

Website: www.co.pierce.wa.us

Information current as of report publish date.

Audit history
You can find current and past audit reports for Pierce County at
http://portal.sao.wa.gov/ReportSearch.

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 ABOUT THE STATE AUDITOR’S OFFICE
The State Auditor’s Office is established in the Washington State Constitution and is part of the
executive branch of state government. The State Auditor is elected by the people of Washington
and serves four-year terms.
We work with state agencies, local governments and the public to achieve our vision of increasing
trust in government by helping governments work better and deliver higher value.
In fulfilling our mission to provide citizens with independent and transparent examinations of how
state and local governments use public funds, we hold ourselves to those same standards by
continually improving our audit quality and operational efficiency, and by developing highly
engaged and committed employees.
As an agency, the State Auditor’s Office has the independence necessary to objectively perform
audits, attestation engagements and investigations. Our work is designed to comply with
professional standards as well as to satisfy the requirements of federal, state and local laws. The
Office also has an extensive quality control program and undergoes regular external peer review
to ensure our work meets the highest possible standards of accuracy, objectivity and clarity.
Our audits look at financial information and compliance with federal, state and local laws for all
local governments, including schools, and all state agencies, including institutions of higher
education. In addition, we conduct performance audits and cybersecurity audits of state agencies
and local governments, as well as state whistleblower, fraud and citizen hotline investigations.
The results of our work are available to everyone through the more than 2,000 reports we publish
each year on our website, www.sao.wa.gov. Additionally, we share regular news and other
information via an email subscription service and social media channels.
We take our role as partners in accountability seriously. The Office provides training and technical
assistance to governments both directly and through partnerships with other governmental support
organizations.

Stay connected at sao.wa.gov Other ways to stay in touch

• Find your audit team • Main telephone:
• Request public records (564) 999-0950
• Search BARS Manuals (GAAP and
cash), and find reporting templates • Toll-free Citizen Hotline:
• Learn about our training workshops (866) 902-3900
and on-demand videos
• Email:
• Discover which governments serve you
[email protected]
— enter an address on our map
• Explore public financial data
with the Financial Intelligence Tool

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