Criminal Law Library Blog

To view the full-text of cases you must sign in to FindLaw.com. All summaries arU.S. 1st Circuit Court of Appeals, February 03, 2010
Janosky v. St. Amand, No. 09-1012
District court's denial of defendant's petition for habeas relief in a case arising out of an armed robbery gone awry is affirmed where: 1) defendant is barred from litigating his procedurally defaulted jury instruction claim; 2) defendant's claim of ineffective assistance of counsel is rejected; and 3) defendant did not present his Sixth Amendment claim regarding a scrap of paper seized from a vehicle fairly and recognizably to the state's Supreme Judicial Court. .

U.S. 1st Circuit Court of Appeals, February 03, 2010
Abrante v. St. Amand, No. 09-1020
Denial of defendant's petition for habeas relief following conviction of armed robbery and related crimes is affirmed where: 1) defendant has not offered clear and convincing evidence that the state established agency relationships with inmate informants who then elicited admissions from him without the presence of counsel in violation of his Sixth and Fourteenth Amendment rights; 2) defendant's due process claim fails; 3) defendant's ineffective assistance of counsel claim is rejected; and 4) the issues defendant raises do not present the court with opportunity to consider his constitutional challenge to the AEDPA. .

U.S. 1st Circuit Court of Appeals, February 04, 2010
Estrada v. State of Rhode Island, No. 09-1149
In plaintiffs' action challenging the constitutionality of the actions of a police officer during a traffic stop, summary judgment in favor of defendant is affirmed where: 1) the officer is entitled to federal and state qualified immunity for any possible constitutional violations that he may have committed in asking the van's passengers questions about their immigration status and in contacting ICE; 2) the officer is entitled to qualified immunity for alleged violations of state or federal laws surrounding the seizure of plaintiffs and their subsequent escort to ICE office; 3) officer is entitled to qualified immunity for both pat down searches under federal and state law; and 4) the officer is entitled to qualified immunity for all of the challenged actions with respect to the Rhode Island Racial Profiling Prevention Act
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U.S. Supreme Court, January 25, 2010
Hemi Group, LLC v. City of N.Y., No. 08–969
In an action by New York City against an online cigarette seller under the civil enforcement provision of RICO, alleging that defendant's failure to file Jenkins Act reports with New York State constituted mail and wire fraud, the court of appeals' judgment reversing the dismissal of the complaint is reversed where plaintiff failed to satisfy RICO's proximate cause requirement because defendant's obligation was to file Jenkins Act reports with the state, not the city, and the city's harm of lost tax revenue was directly caused by cigarette customers, not defendant.

U.S. 1st Circuit Court of Appeals, January 25, 2010
US v. Alfonso-Reyes, No. 06-1484
Convictions of defendants for defrauding the Farm Service Agency (FSA) of emergency loans and incentives to qualified farmers following the damage inflicted on the Commonwealth of Puerto Rico by a hurricane is affirmed where: 1) evidence is sufficient to support defendants' convictions; 2) district court did not abuse its discretion by instructing the jury on sentencing enhancements; 3) district court did not abuse its discretion in its pre-trial disqualification of a defendant's attorney; 4) district court's imposition of a 27-month sentence defendant is not unreasonable; and 5) district court did not err in awarding a four-point leadership role enhancement on the other defendant.

U.S. 1st Circuit Court of Appeals, January 25, 2010
Gray v. Brady, No. 08-2548
District court's denial of defendant's request for habeas relief, convicted of distributing cocaine and for doing so in a public park, is affirmed where: 1) defendant's arguments that the trial court mistakenly believed that defendant, because he is not Hispanic, could not object to the exclusion of an Hispanic juror is without merit; 2) defendant's argument that the state courts wrongly ignored the evidence of discriminatory animus toward the African-American jurors in finding no discriminatory animus against the Hispanic juror is without merit; and 3) defendant's argument that the state courts erred in evaluating the challenges to the Hispanic juror and the African-American jurors separately, as opposed to challenges directed at "minority jurors" as a class is without merit, as defendant has provided no evidence or authority for the proposition that "minorities" constitute a cognizable group for Batson purposes.

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Top Ten Stories for Week Ending February 5, 2010:

Banking Law
Lawyer Sues Sallie Mae Over 'Unrelenting' Student Loan Robocalls
Feb 3, 2010, 06:53 am CST

Legal Marketing & Consulting
Thomson Reuters Buys Super Lawyers
Feb 2, 2010, 02:42 pm CST

Layoffs
Howrey Lays Off 29 Associates and 65 Staffers
Feb 3, 2010, 07:47 am CST

Midyear Meeting 2010
ABA Commission Proposes Independent Court to Help Fix 'Broken Immigration System'
Feb 2, 2010, 09:07 am CST

Plus: Recession Hurting Legal Profession's Diversity Efforts, Report Says
Criminal Justice
South Carolina Lawyer Is Shot and Killed Outside His Office
Feb 4, 2010, 06:29 am CST

Careers
Jones Day: NALP Plan for Delayed Job Offers Is Radical and Anticompetitive
Feb 1, 2010, 12:07 pm CST

U.S. Supreme Court
Catcalls and Muttering Keep Justice Thomas Away from State of the Union
Feb 3, 2010, 07:22 am CST

Careers
Another Attorney Leaves the Law to Drive a Cupcake Truck
Feb 1, 2010, 08:00 pm CST

Plus: Want to Leave the Law? Ex-Lawyer Explains the Upside
Legal Ethics
Judge Rapped Over Order to Pay Class Action Attorney in Store Coupons
Feb 2, 2010, 06:43 pm CST

Work/Life Balance
How Lawyers Can Help Depressed Colleagues
Feb 3, 2010, 05:30 am CST

Prepared by Michael Chernicoff

http://www.abajournal.com/news/article/exclusive_inside_the_new_westlaw_lexis_bloomberg_platforms/#ecamp=t-n322

Despite coming out with new platforms of their own, the perceived‐legal research monopoly of “Wexis” – WestLaw and LexisNexis – is facing pressure from a newly rejuvenated Bloomberg platform. Benefits of the updated Westlaw platform includes the use of a powerful natural language search in the newly‐named WestlawNext, and in the case of Lexis Nexis an intuitive display of results in their product, NewLexis.

The potential release of BloombergLaw marks the company’s expansion of their research product onto personal computers. Historically, the Bloomberg legal research product, B‐Law, was restricted to the Bloomberg Terminal. Currently still running in the Beta version in universities and select New York City law firms, advantages of BloombergLaw include its dockets search and collaboration features, citation analysis, and strength‐of‐authority indicators.

Some expect law firms to see the benefit, with increased competition expected to bring down prices for online legal services.

Point of disclosure. The New York Supreme Court Criminal Term Library has participated as one of the pilot test sites for the Beta version of BloombergLaw.

We are not court reporters and normally do not become involved in discussions related to that field. Nevertheless we recently came accross an interesting exchange of e-mails which helps to identify and highlight the challenges and sometimes emotial reactions regarding how stenographic reporting and electronic recording relate to one another within the court reporting process.

The first e-mail, which we refer to as a comment, presented here in exerpted form, raises concerns about the impact of increased digitization of the process and a percieved lack of planning and resources to deal with these impacts.

The second e-mail is a response to the first. It defends some of the issues criticized in the first e-mail and presents an altervative perspective regarding the roles of stenographic reporting and electronic recording in the court reporting process.

Because of the nature of the exchange and the need to respect privacy we have deleted all identification information regarding either party

COMMENT (EXCERPT) :

:The reports prepared by NACM or reports by other groups sponsored by the National Center for State Courts should be prepared with the help of fine court staff who have spent years and dedicated their careers to expertly recording and preparing court transcripts.

As they say in the appellate courts, there is court reporter dissent with the recommendations of the National Association of Court Management and the recommendations of the Conference of State Court Administrators.

All court reporters who have ever worked in a courtroom and recorded court proceedings will strongly disagree with above mentioned findings and recommendations by NACM and the Conference of State Court Administrators.

Professional court reporters of all types have high standards, and it is not high standards to have the proceedings of several courtrooms monitored from a remote location.

Professional court reporters have high standards and would would never recommend wrapping court reporter notes in rubber bands and storing those notes in metal filing cabinets and then having to later empty those cabinets and file the records in cardboard boxes for permanent storage.

I believe it is the duty and responsibility of those who are skilled in court reporting to challenge reports put out by NACM and the Conference of State Court Administrators when skilled court reporters believe the recommendations made by NACM and the Conference of State Court Administrators are not in the best interests of the court systems or the best interests of the taxpayers when expensive unneeded metal filing cabinets are recommended for the storage of court reporter records.

Court reporters should speak up when the court administrators recommendations give bad advice.

RESPONSE:

Lets try to remove the hysterics from this issue, ... It is not an either/or choice of stenographic reporting or electronic recording. With the exception of Kentucky, every state I am aware of that has grappled with this has ended up with a blended solution of both methods of capturing the verbatim record. As the NACM Miniguide on this subject points out, court managers should go over several considerations to determine the best method to suit the circumstances depending upon such things as case type, likelihood of the need for a transcript and available resources.

As to the other matters you raise, in order to be effective, electronic recording equipment should be monitored by qualified internal or contract staff. The Florida courts have recommended a formula for how many courtrooms a monitor could handle simultaneously, again depending upon several factors. Their report has loads of helpful information about the effective use of electronic recording, and can be found at http://www.flcourts.org/gen_public/court-services/bin/TCPACtReportingFinalReport.pdf

Finally, stenographic notes should be stored electronically, not in paper form. Who cares about the shelf life of rubber bands or whether notes should be stacked vertically or in hermetically sealed boxes?

Stenographic reporting is an honorable profession and there is a rightful place in the making of the court record for steno, especially if the reporter offers realtime and the host of technology advances that come with computer aided transcription. This combination is the platinum standard, but courts do not always need a Cadillac solution especially in these tough budgetary times.

I would much prefer that court reporters bring their expertise about the record to the table to help court management make informed decisions that benefit the system as a whole. Inflammatory rhetoric such as yours only harms this cause, in my view.

BY: Michael Chernicoff

President Barack Obama's nominee to head the Justice Department's Bureau of Justice Statistics (BJS) has promsed to make its statistical body free from political manipulation. In making an independent statistical body, James Lynch may hope to reverse that likelihood that the BJS and its official are, "inappropriately treated in the future."

In 2009, James Lynch was a member of the Panel to Review the Programs of the Bureau of Justice Statistics of the Committee on National Statistics (CNSTAT), which provided recommendations to the Bureau of Justice Statistics (BJS) on ways to improve the quality, creditability, and relevance of U.S. justice statistics. In that report, the Panel recommended that "BJS be moved out of OJP (Office of Justice Programs)," and further suggested, "that the position of BJS director be made a fixed-term presidential appointment with Senate confirmation." (A full-text copy of this report behttp://www.nap.edu/catalog/12671.html).

The Bureau of Justice Statistics was created under the Justice System Improvement Act of 1979, Public Law 96-157 (the 1979 Amendment to the Omnibus Crime Control and Safe Streets Act of 1968, Public Law 90-351) on December 27, 1979. According to their website, the mission of BJS purpose is to, "collect, analyze, publish, and disseminate information on crime, criminal offenders, victims of crime, and the operation of justice systmes at all levels of government."

A hearing to confirm James Lynch's nomination was held on January 20th, 2010.

Sources:
http://bjs.ojp.usdoj.gov
http://www.justice.gov/usao/eousa/foia_reading_room/usab5205.pdf
http://mainjustice.com/2010/01/20/justice-statistics-nominee-pledges-independence/
http://www.nap.edu/catalog/12671.html

As almost everyone knows, the 2011 U.S. Budget was submitted on February 1. Since this is such a huge budget, in terms of both bulk and scope, we have decided to limit this posting largely to links to some " Budget Fact Sheets" prepared by the Office of Management and Budget. Each separately linked fact sheet focuses on a particular priority or group of priorities related to this budget request, thus enabling you to quickly "pick and choose" those areas that interest and concern you without devoting considerable time to other parts of the budget. If you wish to examine this budget request in greater detail, go to the GPO Access link at the end of this posting.

Here are links to the Budget Fact Sheets::

Keeping America Safe and Secure

Clean Energy

Suppoting World Class Education for Children

Create Industries and Jobs

Secure and Affordable Health Care

Supporting America's Military Families

Supporting America's Middle Class Families

Supporting Our Nation's Seniors

Opening Doors for College and Opportunity

Those who are interested in more extensive regarding Budget for the U.S. Governmenrt for fy 11 can go to the GPO Access site at http://www.gpoaccess.gov/usbudget/index.html and follow the various links at that location,

SigInt Technologies, LLC seeks a Senior Level Digital Library Programmer
Analyst to support a US Government Agency.

Salary range: $125,000.00 - $135,000.00

We are growing our hardcopy-centric collection to include a substantial
amount of digital content. You will have the opportunity to chart the course
as we incorporate a variety of electronic data sources into the collection
and make them available to our users. You will have the freedom to select
the tools you deem best and implement them as you see fit. You'll work
directly with library management to collect requirements and propose and
implement solutions. You will lead and direct other developers who will
assist with the implementation.

A masters degree in Library Science, Computer Science, or comparable is
required. Knowledge of Koha, MARC records, Linux, and a scripting language
such as Perl or Python is also required. Experience with PHP, Java/J2EE,
Tomcat, MySQL, STILAS, VuFind, and SOLR is preferred, but not required.

SigInt Technologies provides an outstanding compensation package, including
a Roth or Traditional 401K plan with 100% matching, full medical benefits, a
technology allowance, paid professional memberships and conferences, and a
very flexible work environment. The salary range is $125,000 - $135,000 and
depends on your level of experience. Ten holidays as well as three weeks of
vacation are included. A yearly allowance of $5,000 is provided for
technology, professional memberships, and conferences. Your contribution of
$16,250 (IRS limit) to your 401K plan will be matched by SigInt Technologies
for a total annual retirement contribution of $32,500.

The job is at Fort Meade, Maryland. You must be able to work on-site at
least three days per week. A security clearance is required. Individuals
already possessing a security clearance are highly encouraged to apply.

--
John S. Roberts
SigInt Technologies, LLC
John -AT- SigIntTech -DOT- COM

Volume3 Number 1 January 2010

From the Desk of David Badertscher

As we begin the new year, it’s an opportune time to assess the cyber security landscape and prepare for what new challenges may lie ahead, as well as what current threats may continue.

What Are the Cyber Trends for 2010?

· Malware, worms, and Trojan horses: These will continue to spread by email, instant messaging, malicious websites, and infected non-malicious websites. Some websites will automatically download the malware without the user’s knowledge or intervention. This is known as a “drive-by download.” Other methods will require the users to click on a link or button.

· Botnets and zombies: These threats will continue to proliferate as the attack techniques evolve and become available to a broader audience, with less technical knowledge required to launch successful attacks. Botnets designed to steal data are improving their encryption capabilities and thus becoming more difficult to detect.

· Scareware – fake/rogue security software: There are millions of different versions of malware, with hundreds more being created and used every day. This type of scam can be particularly profitable for cyber criminals -- as many users believe the pop-up warnings telling them their system is infected and are lured into downloading and paying for the special software to “protect” their system.

· Attacks on client-side software - With users keeping their operating systems patched, client-side software vulnerabilities are now an increasingly popular means of attacking systems. Client-side software includes things like Internet browsers, media players, PDF readers, etc. This software will continue to have vulnerabilities and subsequently be targeted by various malwares.

· Ransom attacks occur when a user or company is hit by malware that encrypts their hard drives or they are hit with a Distributed Denial of Service Attack (DDOS) attack. The cyber criminals then notify the user or company that if they pay a small fee, the DDOS attack will stop or the hard drive will be unencrypted. This type of attack has existed for a number of years and is now it is gaining in popularity.

· Social Network Attacks: Social network attacks will be one of the major sources of attacks in 2010 because of the volume of users and the amount of personal information that is posted. Users’ inherent trust in their online friends is what makes these networks a prime target. For example, users may be prompted to follow a link on someone's page, which could bring users to a malicious website.

· Cloud Computing: Cloud computing is a growing trend due to its considerable cost savings opportunities for organizations. Cloud computing refers to a type of computing that relies on sharing computing resources rather than maintaining and supporting local servers. The growing use of cloud computing will make it a prime target for attack.

· Web Applications: There continues to be a large number of websites and online applications developed with inadequate security controls. These security gaps can lead to the compromise of the site and potentially to the site’s visitors.

· Budget cuts will be a problem for security personnel and a boon to cyber criminals. With less money to update software, hire personnel and implement security controls enterprises will be trying to do more with less. By not having up-to-date software, appropriate security controls or enough personnel to secure and monitor the networks, organizations will be more vulnerable.

What Can I Do?

The following are helpful tips to assist in minimizing risk:

· Properly configure and patch operating systems, browsers, and other software programs.

· Use and regularly update firewalls, anti-virus, and anti-spyware programs.

· Be cautious about all communications; think before you click. Use common sense when communicating with users you DO and DO NOT know.

· Do not open email or related attachments from un-trusted sources.

Additional Information:

IBM’s Top Security Trends for 2010: http://www.internetnews.com/security/article.php/3849636/

Symantec’s 'Unlucky 13' Security Trends for 2010:
http://www.internetnews.com/security/article.php/3849371

SANS Top Cyber Security Risks: http://www.sans.org/top-cyber-security-risks/

Bankinfosecurity.com article: http://www.bankinfosecurity.com/articles.php?art_id=1926

PC World: http://www.pcworld.com/article/182889/new_banking_trojan_horses_gain_polish.html

Panda Labs 2009 Annual Malware Report:
http://www.pandasecurity.com/img/enc/Annual_Report_Pandalabs_2009.pdf

The above comments are based on information tips provided by the Multi-State Information and Analysis Center (MS-ISAC). To learn more about MS-ISAC go to http://www.msisac.org/

OTHER NEWS AND VIEWS:

DARPA: Calling All Cyber Geneticists
Technology sought would develop cyber equivalent of DNA to identify cyberattackers

By Ben Bain
Jan 29, 2010
Federal Computer Week
"The Defense Advanced Research Projects Agency is looking for technologists who can think like scientists to develop and use the cyber equivalent of fingerprints or DNA to pinpoint the origins of a cyberattack...."
____________________

False sense of cybersecurity
Paul Bell
GCN Government Computer News
January 13, 2010.
Newly appointed National Cybersecurity Coordinator Howard Schmidt has a big job ahead of him. Getting individuals, businesses and government to take greater responsibility is one of three places he should start

Although addressed primarily to Internet Society members, the following message contains information which should be of interest to librarians, lawyers and other important stakeholders in the internet community who need to follow ongoing developments.

Dear Members, Friends, and Colleagues,

The end of 2009 is here - and what a year it has been. The Internet
Society continued to prosper in 2009, the results of our work reaching
wider and deeper than ever before. So it is a pleasure to extend my
sincere gratitude to all of you whose combined efforts, energy, and
dedication have made this such a great year.

We often use the term "Internet community" and, looking back at the
achievements of this year, it is clear that these are truly the result
of a strong, committed community pulling together around shared values
and principles.

It is impossible to list here all of the Internet Society's
achievements from such a busy and productive year, but I would like to
single out a few highlights.

Within the Enabling Access Initiative, we worked closely with Chapters
and other local and regional partners to significantly extend our
technical and policy capacity building programmes, especially in
Africa, Latin America, and the Caribbean. These efforts were aided
through a revitalized INET programme with specialized content
developed in partnership with local communities, and which reached out
successfully to hundreds of participants in each location. This work
advanced our profile and strengthened our message in many high-level
forums, such as the OECD, the World Bank, and the ITU. Access
continues to be one of the major themes in many of the Chapter and
other member projects supported by our grants programmes.

In our InterNetWorks Initiative, a number of new efforts contributed
to helping to advance the health of the Internet. ISOC continues to
project a strong voice for IPv6 deployment, so it has been pleasing to
see in 2009 that IPv6 is gathering momentum around the world. In an
exciting new development this year, ISOC launched a series of topical,
lively panel discussions during IETF meetings. The first on IPv6
deployment attracted much international attention. Together with the
subsequent panels on DNS security and bandwidth management issues,
these events have set the scene for what will be an important ongoing
activity, helping to advance the health of the Internet and promoting
the role of the IETF.

ISOC's Trust and Identity Initiative benefited from two important new
staff additions in 2009, increasing our involvement in many important
new initiatives and partnerships in both the Trust and Identity
spaces. One of the most significant is the Kantara Initiative
(formerly the Liberty Alliance), in which ISOC has developed a strong
voice and leadership role.

Throughout all of our work in 2009, we strived to promote better
understanding of the nature and importance of the Internet Model of
development and the relationships of the many organizations and
functions making up the Internet Ecosystem. These efforts have clearly
paid off and we were very pleased to see many of our messages
reflected in the words and actions of many others in regional,
national, and global discussions. In 2009, ISOC's key messages were
more frequently cited in media reports and reflected in statements by
policy makers around the world than ever before.

Additions to ISOC's staff in 2009 helped us make big strides in
producing better publications and communications resources, delivering
important information and services in more languages, and providing
much greater support for events where Chapters, Individual and
Organization Members, and others come together in support of our
common mission. The successful Sphere project continues to be an
excellent process for enabling the full potential of the Chapter
network. And we were very pleased to recently launch the first phase
of our new Association Management System as a much improved tool for
Chapter and member interaction.

This year was one of ISOC's most significant ever in terms of global
engagement. With highly visible roles in the EU, ITU, OECD, IGF, and
many other major policy and technical forums, it is clear that ISOC's
reputation as a trusted and authoritative voice on critical Internet
issues continues to grow stronger. We again were honoured to
coordinate the participation of other organizations, especially in the
Internet Technical Advisory Committee to the OECD and the Internet
Pavilion at the ITU's Telecom World 2009. At the latter event, ISOC
announced the Next Generation Leaders programme, a new activity
starting in 2010 to build on our past successes such as the Network
Training Workshops (NTW's), as well as our current work in Fellowships
to the IETF, and Ambassadorships to the IGF and other forums, adding
coursework and mentoring to help accelerate the careers of the young
practitioners who will lead the Internet into its next generation.

Finally, the Internet Society is finishing the year on a high note,
having just announced our support for the World Wide Web Consortium
(W3C), to help it evolve as a more agile, inclusive, and flexible
organization, as it creates and promotes open standards.

There is so much more I could mention here - it really has been an
extraordinary year. As 2009 draws to a close, it is important to
recognize and thank all those who contributed to such a successful
year. So, thank you to all the Individual and Organization Members,
the Chapters, and all our other supporters and partners for their
efforts and support as we worked together in pursuit of our common
goals. Thank you to our friends in the Internet Engineering Task Force
(IETF) and the Internet Architecture Board (IAB) without whose values
and work, the Internet, as we know it, would not exist. And, of
course, thank you to the ISOC staff, the ISOC Board of Trustees, the
Organization Member Advisory Council and the Public Interest Registry
(PIR), for their efforts and support. To all of you, your support is
vital to helping the Internet improve the lives of people everywhere.

Finally, I'd like to extend my very best wishes to you and your
families during the holiday season, as we couldn't do what we do
without their support. I look forward to working together with all of
you for a prosperous and successful 2010.

Warmest regards,

Lynn

Lynn St.Amour
President & CEO, Internet Society

Volume 2 Number 1
January 7, 2010

State Courts & the Economy is an e-newsletter published by the National Center for State Courts.

Contents of this issue:

Courts Starting to Bear the Brunt of the Recession
Close Some Courthouses, But Build New Ones, Too?
Budget Cuts Go to Court
State-by-State Budget News

OCLC's QuestionPoint and Mosio's Text a Librarian announce virtual reference collaboration
Project to offer text messaging reference options to QuestionPoint users. Here is the Press Release :

DUBLIN, Ohio, January 15, 2010-OCLC and Mosio are working together to enable seamless integration of Mosio's Text a Librarian text messaging reference software with OCLC's QuestionPoint reference management service to provide a comprehensive virtual reference solution for libraries.

OCLC and Mosio are exploring solutions to the demands of a mobile world and the need for libraries to be able to communicate with their patrons online and on-the-go.
"Library reference services need to be accessible where and when users need them, in the form they want," said Jay Jordan, OCLC President and CEO. "Users are increasingly relying on mobile technologies, and QuestionPoint is committed to providing libraries with the tools they need. Text a Librarian is a leader in texting services for libraries in the U.S. Working together, we believe we can deliver an efficient and cost-effective solution for libraries."

QuestionPoint's reference management suite that includes email, online chat and chat widgets combined with Mosio's Web-based Text a Librarian service for text messaging would offer patrons more virtual reference options and provide libraries increased efficiencies in managing patron inquiries in a single place.

"Mobile reference services are an exciting opportunity for libraries," said Noel Chandler, Mosio CEO and Co-Founder. "This collaboration combines our expertise in mobile reference technology with OCLC's experience as the leader in virtual reference management software to provide libraries a full digital reference services package."

The integration of Text a Librarian with QuestionPoint services will begin with libraries based in the United States.

For more information, visit www.textalibrarian.com or www.oclc.org/questionpoint.

About OCLC
Founded in 1967, OCLC is a nonprofit, membership, computer library service and research organization dedicated to the public purposes of furthering access to the world's information and reducing library costs. More than 72,000 libraries in 112 countries have used OCLC services to locate, acquire, catalog, lend, preserve and manage library materials. Researchers, students, faculty, scholars, professional librarians and other information seekers use OCLC services to obtain bibliographic, abstract and full-text information when and where they need it. OCLC and its member libraries cooperatively produce and maintain WorldCat, the world's largest online database for discovery of library resources. Search WorldCat on the Web at www.worldcat.org. For more information, visit www.oclc.org.

About Mosio's Text a Librarian
Text a Librarian is a mobile reference service technology developed specifically for libraries. Built on Mosio's award-winning mobile questions and answers platform, Text a Librarian enables libraries to reach more patrons on the go through their mobile phones. For more information regarding Text a Librarian, please visit www.textalibrarian.com