Monthly Archives: April 2014

Fixing the Internet Explorer Bug.

30 Wednesday Apr 2014

Posted by in Computer Virus, Law Office Management, Legal Technology, Search Enginges

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FIXED – Internet Explorer Bug-Of-The-Day, by Nerino Petro, Compujurist Blog

http://bit.ly/1hUNhbI

Here is a great video and post with steps on how to protect yourself from the IE monster affecting ALL versions of IE  that has been making news this week. Steve Gibson created the initial steps but left out a few things. Terry Cole from Cole Informatics added these and created the video and post. If you’re running Windows XP, you especially need to check this out. See it here.

Seeking Solutions To Reduce Recidivism.

30 Wednesday Apr 2014

Posted by in Criminal Law, Justice Reform

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The Utah Association Of Counties Explores Solutions To Reduce Recidivism, by Will Engelhardt, Policy Analyst, Justice Center, The Council of State Governments

http://tinyurl.com/mhzeblr

In January 2014, the Utah Association of Counties invited national experts to lead a training event on recidivism reduction for its members. Council of State Governments Justice Center (CSG Justice Center) Director Michael Thompson and Jake Horowitz of The Pew Charitable Trusts’ Public Safety Performance Project presented on national research on and trends in recidivism reduction, tracking recidivism rates, and the role of community-based behavioral health care services in reducing recidivism. The daylong event, entitled ‘One and Done: Four Strategies to Reduce Recidivism in Utah’s Prison System,’ brought together more than 60 representatives from Utah’s county and state governments to discuss issues related to recidivism.

The event offered an opportunity for criminal justice policymakers from around the state to connect and share insights about challenges facing counties in Utah.  Policymakers also discussed potential strategies to address these challenges at the state level using the bi-partisan, data-driven justice reinvestment approach, as well as employing a targeted, county-level research-based effort. . . .

Benchslap Open Season on Acronyms.

30 Wednesday Apr 2014

Posted by in 9th Circuit Court of Appeals, Acronyms, Appellate Law, Bad Legal Writing, District of Columbia Circuit Court of Appeals, Legal Writing, Legalese, Readability

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Alphabet Attack, by Ross Guberman’s Legal Writing Blog

http://legalwritingpro.com/blog/alphabet-attack/

It wouldn’t be spring in America without some federal judges publicly criticizing attorneys in a genre now known as ‘benchslap.’

The offended court this time: the D.C. Circuit. The court’s target: acronyms in briefs filed in a complex telecom dispute. The benchslap: “’It is ordered . . . that the parties submit new briefs that eliminate uncommon acronyms used in their previously filed final briefs.’ The court even cited its own practice handbook for good measure: ‘[i]n briefs the use of acronyms other that those that are widely known should be avoided.’ . . .

The Art of Cross-Examination.

28 Monday Apr 2014

Posted by in Cross-Examination, Trial Tips and Techniques

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Some Thoughts About Cross Examination, by Paul N. Luvera, Plaintiff Trial Lawyer Tips

http://plaintifftriallawyertips.com/some-thoughts-about-cross-examination

London barrister Peter Brown wrote a book some years ago entitled ‘The Art of Questioning.’  In one chapter he wrote: Last summer, a motorcyclist was arrested in Oxford, England, for speeding. The lady prosecutor bore in on the defendant with a curved question:  ‘Mr. Setright, your motorcycle is capable, is it not, of exceeding the 70 mph speed limit? He answered: Certainly it can exceed that limit. But, the possibilities implicit in that physical ability are it relevant to these proceedings. We are not here to consider what I might have been doing, but for the prosecution to prove, if it can, that I was doing what they allege I was doing. Were it otherwise you might just as well be here accused of rape, simply on the grounds that I have the necessary apparatus.’ . . .

More on Link Rot.

27 Sunday Apr 2014

Posted by in Appellate Law, Legal Technology, Link Rot, United States Supreme Court

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Stopping Link Rot: Aiming to End A Virtual Epidemic, by NPR Staff, All Tech Considered, NPR

http://n.pr/QTrCGp

I have mentioned perma.cc and the problem of link rot before. It is a good solution but not quite perfected. When I have used it here on this blog, it is not always reliable, which is disappointing for something that shows such promise. Hopefully all the kinks will be worked out soon. -CCE

Just about anyone who’s gone online has encountered the message: ‘Error 404’ or page ‘Not Found.’ It’s what you see when a link is broken or dead — when the resource is no longer available.

It happens all across the Internet, on blogs, news websites, even links cited in decisions by the Supreme Court. It’s called link rot, and it spreads over time as more pages die.

These are natural deaths; links die when the server where the page first lived has closed for business, or a filter is blocking access. It’s annoying on sites like Buzzfeed and Gawker, but it’s worse when links go rotten on judicial decisions or works of scholarship.

Jonathan Zittrain, professor of law and computer science at Harvard University, says that’s a serious problem.

‘It’s extraordinarily bad for the long-term maintenance of the information we need, say, to understand the law,’ says Zittrain, who helped create Perma.cc, a service to help judges, authors and scholars preserve links indefinitely. . . .

Worst Passwords in 2013.

27 Sunday Apr 2014

Posted by in File Naming Conventions, Law Office Management, Legal Technology, Office Procedures, Passwords

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 The 25 Worst Passwords Of 2013: ‘Password’ Gets Dethroned, by Jared Newman, PC World

http://bit.ly/1ePbr3c

‘123456’ is finally getting some time in the spotlight as the world’s worst password, after spending years in the shadow of ‘password.’

Security firm Splashdata, which every year compiles a list of the most common stolen passwords, found that ‘123456’ moved into the number one slot in 2013. Previously, ‘password’ had dominated the rankings.

The change in leadership is largely thanks to Adobe, whose major security breach in October affected upwards of 48 million users. A list of passwords from the Adobe breach had ‘123456’ on top, followed by ‘123456789’ and ‘password.’ The magnitude of the breach had a major impact on Splashdata’s results, explaining why ‘photoshop’ and ‘adobe123’ worked their way onto this year’s list.

Fans of ‘password’ could reasonably petition for an asterisk, however, given that the stolen Adobe passwords included close to 100 million test accounts and inactive accounts. Counting those passwords on the list is kind of like setting a home run record during batting practice. Don’t be surprised if “password” regains the throne in 2014. . . .

Obama’s New Clemency Initiative.

27 Sunday Apr 2014

Posted by in Clemency, Criminal Law, Department of Corrections, Justice Reform

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Three Things Obama’s New Clemency Initiative Doesn’t Do, by Kara Brandeisky, ProPublica

http://tinyurl.com/lury8bw

Today [April 23, 2014], the Department of Justice outlined expanded criteria that could allow prisoners convicted of non-violent crimes to win early release from prison. Under the new initiative, the Office of the Pardon Attorney will fast-track commutation applications from inmates who have served more than 10 years for non-violent offenses and who were well-behaved while imprisoned.

As part of the shift, the department is replacing Pardon Attorney Ronald Rodgers. Two years ago, we reported that Rodgers had failed to provide critical information to the White House in urging denial of a commutation for Clarence Aaron, a model prisoner who served nearly 20 years for a small role in a drug deal. . . .

Making Sense When Writing For Non-Lawyers – It’s Not That Hard.

27 Sunday Apr 2014

Posted by in Bad Legal Writing, Legal Writing, Legalese, Readability

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Why Are The Lawyers Pestering Us? Communicating About Law And Compliance, by Mark Herrmann, Above The Law Blog (with hat tip to Raymond Ward, the [new] legal writer blog)

http://tinyurl.com/mu8vg7g

At a law firm, law matters. Law is the center of the institution’s universe, and it’s all everyone is thinking about.

It’s the other functions that don’t matter: ‘Another email from IT? Telling me about interfaces and gigabytes? Why don’t those clowns leave me alone?’

‘Another email from finance hectoring me about time sheets? Don’t those morons know I’m busy?’

At corporations, law (and compliance) is an ‘other function.’ The businesses are concentrating on their businesses, and law and compliance — along with human resources, information technology, and finance — are, at best, a means to an end. If you mirror the other ‘shared services’ and send incomprehensible communications to the businesses, the businesses will soon realize that you’re just one of the pests, meant to be ignored.

Inevitably, if a business person accidentally steps over some legal line, you’ll hear that the business guy had no clue that the line existed: ‘Yeah, yeah. Now that you’re telling me about it, I understand that we have that rule. But how was I to know? The rule is buried on the fourth page of some impenetrable policy hidden somewhere in our computer system. I spend my time selling; I can’t waste time trying to make sense of your legalese.’

If you don’t sympathize with that guy, then you’ve been a lawyer for too long. His criticism is not just an excuse for having violated the rules; his criticism may well be the truth. How can you change that reality? . . . .

New Standard for Proving Sexual Harassment.

27 Sunday Apr 2014

Posted by in Appellate Law, Employment Law, Gender Discrimination, Harassment, Hostile Work Environment, Sexual Harassment

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Two New Cases Demonstrate High Bar For Proving Sexual Harassment, by Parker Poe Adams & Bernstein LLP, Lexology®, in cooperation with Association of Corporate Counsel

http://tinyurl.com/luwkehs

Not all sex-related behavior in the workplace gives rise to an actionable claim for sexual harassment. In order to violate Title VII, the actions complained of must be unwelcomed, and must create a hostile and offensive working environment based on the victim’s gender. Two new federal appellate cases show how alleged workplace behavior can be obnoxious and unwelcomed, and yet still fail to reach this threshold. . . .

South Carolina Supreme Court Gives Thumbs’ Up to LegalZoom.

27 Sunday Apr 2014

Posted by in Appellate Law, Legal Ethics, Legal Forms, Legal Technology, South Carolina Supreme Court

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LegalZoom Gets Nod From South Carolina Supreme Court, posted by Greg Lambert, Three Geeks and a Law Blog

http://www.geeklawblog.com/2014/04/legalzoom-gets-nod-from-south-carolina.html

The term ‘Access to Justice’ (A2J) is tossed around a lot in the legal world, but as the old saying goes, talk is cheap. It is common for state bar associations to step up and use another phrase to shoot down A2J projects or non-lawyers’ attempt to fill a gap in the legal process that is underserved. In most cases, it is seen as a ploy to protect the Bar Association’s members . . . at the expense of those needing help with a complicated legal system. One of the most contentious issues is on basic legal forms. Companies like LegalZoom have stepped in to create forms for the individual citizen, and have found many states are very reluctant in approving of their products and services. . . .

What The Nokia-Microsoft Union Means For You.

27 Sunday Apr 2014

Posted by in Android Phones, Cell Phones, Legal Technology, Tablets

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With This Phone, I Thee Wed, How the Nokia-Microsoft Union Changes Everything, by Brad Chacos, PC World

http://tinyurl.com/msqgfnw

There’s no getting cold feet now. On Friday, Microsoft’s acquisition of Nokia’s device business  will be official, after months of delays and regulatory hurdles. The remnants of Nokia will get a whopping $7.2 billion. In return, Microsoft will get 25,000 new employees, a legion of Lumias, and oh yeah, those funky Android-based Nokia X phones.

So what?

Sure, Microsoft and Nokia each stand to gain (or lose) billions from the deal. But why does that matter to you? What should you and I hope to see from the Microkia conglomerate, in terms of Windows Phones and devices that we can actually touch and hold and feel? I’m glad you asked. . . . .

Powerful PowerPoint Courtroom Presentations.

27 Sunday Apr 2014

Posted by in Closing Argument, Experts, Jury Persuasion, Legal Technology, Opening Argument, PowerPoint, Presentations, Technology, Trial Tips and Techniques

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Adding Power to Courtroom Presentations, posted by Elliott Wilcox, TrialTheater Blog

http://tinyurl.com/lddsa49

I ran across this blog today, and I like what I see. PowerPoint is a powerful tool. Like you, I have seen far too many poor presentations.

A good power PointPresentation is an art. It doesn’t just happen. If you have never bothered to find out whether there are guidelines or rules for a good PowerPoint presentation, then you may be guilty, regardless of how witty, entertaining, or persuasive you think you are.

Take some time to read all you can about what makes a good presentation. Do not read your slides. Instead, let them compliment what you say or let them be the “punchline” to your idea. Pay attention to font size. Resist the temptation to fade in, face out, and use dancing graphics that scamper across the screen in every slide.

This post from TrialTheater will tell you how.  Please also note that there are additional posts listed at the end that are also interesting. This is a blog I plan to watch more closely. –CCE

The lights dim, and the first slide appears. You think to yourself, “Oh no, another boring PowerPoint presentation.” The first line of text soars in from the left, each character twirling and dancing across the screen. You count eleven bullet points on the first screen (the shortest of which is sixteen words long). The second slide is even more confusing. The third is a picture of his kids. Fortunately, the room is dark, so no one notices as you start to fall asleep…

Why are most PowerPoint presentations so dreadful? When was the last time you saw a presentation that was actually enhanced by PowerPoint? The reason PowerPoint decimates the effectiveness of most presentations is because the presenters don’t understand how or why to use it. But, when you need to illustrate a point in the courtroom, PowerPoint can be a tremendous addition to your trial skills toolbox. This article will give you tips for improving your presentations, both inside and outside the courtroom. . . . .

Marijuana Legalization Webinar Slides.

26 Saturday Apr 2014

Posted by in Criminal Law, Drug Possession, Health Law, Medical Marijuana

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Webinar Slides: Marijuana Legalization – The Legal Ins and Outs, by Tim Baran, Legal Productivity Blog

http://tinyurl.com/l2d3qyx

Here’s the slide deck from today’s terrific webinar: Marijuana Legalization – The Legal Ins and Outs for Cannabis Business Clients with Marijuana Industry Attorney of the Year, Hilary Bricken.

Find out what attorneys and their marijuana business clients need to know. Topics include: general licensing process with various state agencies, local law implementation and litigation, medical versus recreational marijuana, trademark registration and protection, taxation, real estate transactions, and banking issues. . . . .

Is Double Hearsay in 911 Call Admissible Evidence?

26 Saturday Apr 2014

Posted by in Court Rules, Evidence, Hearsay, Trial Tips and Techniques

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Rescue 911: Court of Appeals of South Carolina Grapples With Double Hearsay Issue, by Colin Miller, EvidenceProf Blog

http://tinyurl.com/le3j6kf

Similar to its federal counterpart, South Carolina Rule of Evidence 805 provides that

Hearsay included within hearsay is not excluded under the hearsay rule if each part of the combined statements conforms with an exception to the hearsay rule provided in these rules.

So, assume that a daughter reports to her mother that she was sexually assaulted and that the mother then calls 911 and relays what her daughter told her. Should the 911 call be admitted? According to the Court of Appeals of South Carolina in State v. Hendricks, 2014 WL 1614844 (S.C.App. 2014), the answer is ‘no.’ . . . .

Today’s U.S. Supreme Court Opinion on Affirmative Action.

22 Tuesday Apr 2014

Posted by in Appellate Law, United States Supreme Court

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Evening Round-Up: Schuette v. Coalition to Defend Affirmative Action, by Kali Borkoski, SCOTUSblog

http://tinyurl.com/m8nung8

I have not yet read the entire opinion, as well as all of the separate opinions. This post provides links to many others that have already analyzed this decision and who wrote what. -CCE

This morning, a divided Court upheld an amendment to the Michigan constitution that prohibits the use of affirmative action by public universities in admissions.  Justice Kennedy announced the judgment of the Court in an opinion that was joined by the Chief Justice and Justice Alito.  Justice Scalia filed an opinion, concurring in the judgment only, that was joined by Justice Thomas, while Justice Breyer filed his own opinion concurring in the judgment. Justice Sotomayor filed a dissenting opinion (joined by Justice Ginsburg) and summarized her dissent from the bench. . . .

Journalist’s Guide to Federal Courts.

17 Thursday Apr 2014

Posted by in Bankruptcy Law, Courts, U.S. Courts of Appeal, United States Supreme Court

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A Journalist’s Guide to the Federal Courts, Administrative Office of the United States Courts

http://www.uscourts.gov/News/JournalistsGuide.aspx

Federal judges and the journalists who cover them share much common ground. One clear area of mutual interest is accurate and informed coverage of federal courts. A Journalist’s Guide to the Federal Courts is intended to assist reporters assigned to court coverage. It is the media who inform and educate the public about the courts, spark discussion and debate about their work, instill public trust and confidence in the institution and its function, and help protect judicial independence. These are worthwhile and important pursuits.

There are justifiable and distinct differences between the three branches of government and the access they grant the news media. Most of the work of federal courts is performed in open court and decisions, and in most cases court filings are available on the Internet. This primer is aimed at helping reporters who cover federal appellate, district, and bankruptcy courts – the cases, the people, and the process.

Download full report (pdf)

 

Keeping Medical Records Costs Down.

16 Wednesday Apr 2014

Posted by in HITECH Act, Litigation, Medical Records, Motor Vehicle, Negligence, Personal Injury, Product Liability, Torts, Wrongful Death

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Defeating The Medical Records Paper Copy Scam, by Max Kennerly, Esq., Litigation and Trial Blog (with hat tip to Evan Schaeffer, The Trial Practice Tips Blog!)

http://tinyurl.com/mmpm4sy

Mr. Kennerly explains why obtaining medical records need not be expensive, and provides a sample letter with citation to legal authority. -CCE

Hardly a day goes by without a letter from my office either requesting medical records or paying for them. Some days, I sign more than a dozen. It’s perhaps the most common thread among all my cases: the vast majority of my clients have been physically injured in one way or another, and at a bare minimum, I need the records from their doctors and hospitals to show the diagnoses they have and the treatment they have received.

Every patient has a right to receive their medical records, and by law should be able to obtain those records promptly at no markup, with no padded fees, and no unnecessary charges from the hospital or the records company. But if there’s money to be made, someone will try to make it, and over the past decade a whole cottage industry has developed around the “business” of trying to cheat patients trying to get their medical records. Sometimes health care providers outsource this ‘business’ to third-party companies, and sometimes the hospitals and health systems play the con game themselves. . . .

Why Isn’t The Judge Listening?

16 Wednesday Apr 2014

Posted by in Closing Argument, Experts, Jury Persuasion, Legal Analysis, Legal Argument, Opening Argument, Trial Tips and Techniques

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Experts: Keep It Comparative, by Dr. Ken Broda-Bahm, Persuasive Litigator Blog

http://tinyurl.com/n3hovpy

The expert has prepared thoroughly for her testimony before the judge. She knows each opinion and every foundation. The outline that counsel developed is all but memorized. But then, as she is about an hour into describing the detailed methods and conclusions, the judge’s eyes are drifting down to the table and the nods of understanding have stopped: He isn’t getting it. In itself, there is nothing in the testimony that is impossible to understand – on the contrary, it is organized and clear. But the judge seems to have disengaged. Instead of tracking with the testimony at each step, he is just hearing detail after detail and letting it wash over him.  And if there were a jury in the room, the problem would be even worse.

What went wrong?  . . . .

How Not To Do E-Discovery.

15 Tuesday Apr 2014

Posted by in Discovery, E-Discovery, Litigation Hold, Preservation, Sanctions

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Fears and Loathing (and Pain) in Seattle: a Case Lesson in How NOT to Preserve and Produce Email – Part One, by Ralph Losey, e-Discovery Team®

http://tinyurl.com/l8ujksu

If e-discovery is part of your life, you need to read this blog. Ralph Losey is not the only expert showcased here, but he is definitely one of the best. E-discovery is an area of law that is constantly evolving. If you do not work in it frequently, it is easy to get lost. Blogs such as these will help. -CCE

A recent case in Seattle provides a text-book example of how not to do e-discovery. It concludes with a sanctions order against the defendant, and the defendant’s law firm, Payne & Fears LLP. The law firm was fined $10,000, payable to the court, due to the conduct of two of its attorneys. The defendant, Corinthian Colleges, was fined another $25,000. Knickerbocker v Corinthian Colleges, Case No. C12-1142JLR, (WDWA, April 7, 2014). . . .

Tech Tips for Document Review, Production, and Trial.

15 Tuesday Apr 2014

Posted by in Discovery, Document Review, Exhibits, Legal Technology, Requests for Production, Subpoena Duces Tecum, Technology, Trial Tips and Techniques

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5 Tech Tips for Document Review, Production and Use at Trial, by Michael Kelleher, Cogent Legal Blog

http://tinyurl.com/kv3jy3f

Mr. Kelleher not only shares the technology tips from his recent webinar, but is kind enough to offer his e-mail address and telephone number should you have any questions. Nice guy! -CCE

On Wednesday, April 9, I gave a webinar on technology tips for document review, production and use at trial for the Law Practice Management and Technology Section of the California State Bar. We’re going to be posting a few of the tips on the blog if you missed the webinar. You can also download a PDF of the slide deck with all 25 tech tips here. I hope that these tips save you some time. Email me (michael.kelleher@cogentlegal.com) or give me a call at 510-350-7616 if you have questions about this or any other aspect of litigation technology. . . .

Private Prison Corporation Sixth Largest U.S. Prison System.

14 Monday Apr 2014

Posted by in Campaign Contributions, Criminal Law, Department of Corrections, Government, Lobbyists

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Backroom Deals in Arizona Enrich Private Prison at Taxpayer Expense, by Olivia Sandbothe, AFSCME

http://tinyurl.com/lksp7ym

A private prison corporation already rakes in $45 million in taxpayer dollars each year in the state of Arizona, with a contract that virtually guarantees the company fat profits no matter how it actually performs.  But that wasn’t enough for the GEO Group, as a recent flap in the Statehouse reveals.

The GEO Group operates 59 private prisons across the United States, making it the nation’s sixth-largest prison system.  Last year the group turned $115 million in profits and paid its CEO nearly $5 million. But they didn’t get there through healthy competition or better business practices. . . .

Clear Legal Writing.

13 Sunday Apr 2014

Posted by in Legal Writing

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Clear Writing Through Purposeful Sentences, by Stephen D. Feldman, Ellis & Winters, LLP

http://www.elliswinters.com/updates/feldman_clear_writing_14

Clear writing makes winning more likely.  Why?

Consider our courts’ workloads.  A federal district court judge, on average, annually handles over five hundred filings.[1]

The federal appellate courts annually receive more than 50,000 appeals.[2]  State courts experience the same pressures.[3]

These docket pressures, however, do not diminish the role of briefs.  If anything, it is enhanced.  Judges—even when they hear oral arguments—regularly make their rulings based on the briefs.[4]  A winning brief, then, must convey to the reader the key points for victory—and do so in one reading. . . .

Author’s Guild Sues Google Inc. For Copyright Infringement.

13 Sunday Apr 2014

Posted by in 2nd Circuit Court of Appeals, Copyright, Intellectual Property

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Authors Guild Asks US Court To Rule Against Google, by Larry Neumeister, Associated Press (Associated Press Writer Michael Liedtke in San Francisco contributed to this report) (with hat tip to Howard J. Bashman at How Appealing Blog!)

 http://tinyurl.com/ya7n7wx

Saying Google Inc. is stealing business from online book retailers, the Authors Guild asked a federal appeals court Friday to reinstate its lawsuit contending that the Internet giant is violating copyright laws with its massive book digitization project.

The Guild filed papers with the 2nd U.S. Circuit Court of Appeals in Manhattan, saying that Google’s effort to create the world’s largest digital library was violating the rights of authors and stifling competition in the busy Internet book sales market. . . .

The Library of Congress’ Virtual Reference Shelf.

13 Sunday Apr 2014

Posted by in Recent Links and Articles, References, Research

≈ 1 Comment

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Virtual Reference Shelf, Library of Congress

http://www.loc.gov/rr/askalib/virtualref.html#abbreviations

Do you for some kind of inexplicable reason want to look up The Guide to Government Abbreviations? It’s here. In fact, the Virtual Reference Shelf has in-depth information on Abbreviations, Art, Business, Calculators, Children & Parents (e.g., The U.S. Government Guide for Kids), Dictionaries & Thesauri, Directories, Education, Encyclopedias, English Language and Literature, Full-Text Books & Periodicals, Genealogy, General Reference Resources, Grant Resources, Health/Medical, U.S. History – and more. Check it out. It is more than you probably expect. -CCE

The Mashable Hit List.

13 Sunday Apr 2014

Posted by in Android Phones, Apps, Cell Phones, Clouds, Computer Virus, Disaster Preparedness, Dropbox, Emails, Encryption, Google, Heartbleed, Identity Theft, Law Firm Web Sites, Law Office Management, Legal Blogs, Legal Technology, Malware, Office Procedures, Passwords, PC Computers, Search Enginges, Technology, Using Social Media

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The Heartbleed Hit List: The Passwords You Need to Change Right Now, The Mashable Team

http://mashable.com/2014/04/09/heartbleed-bug-websites-affected/

If you wondered whether any main specific websites are affected, such as Yahoo, this list will help you.  It will also help explain the Heartbleed bug,  and why you should pay attention to what it is. If you want to know whether your specific bank was compromised, this list may not answer all your questions. So, if you’re not sure whether you should change your password, go ahead and do it.

Even better, find a password manager in this list of the best of the best from PC Magazine by Neil J. Rubenking — http://www.pcmag.com/article2/0,2817,2407168,00.asp. If you use one password for more than one website — and lots of people do — this is a good solution and a wise move regardless of the Heartbleed bug. -CCE