ERIC H. ARCHER 
                   Attorney and Counsellor at Law 
                      CA State Bar Number 75714 
                     Also admitted In New Jersey 
                     1630 North Main Street #374 
                        Walnut Creek CA 94596 
                       Voice/FAX 510-934-1846 
 
                            11 March 1997 
 
Appellate Court and Circuit Administration Division 
ATTN: ABA Citation Resolution 
Ste 4-512 
Administrative Office of the United States Courts 
Washington DC 20544 
 
VIA FAX TO 202-273-1555 
 
Greetings: 
 
     It is my opinion that the Americans With Disabilities Act and 
social conscience mandate adoption of format neutral citations such 
as those proposed by the American Bar Association. Perpetuation of 
proprietary citation systems will continue to discriminate against 
users who are disabled or of limited means as follows: 
 
     o Few sole practitioners can afford to house, let alone buy, the 
       proprietary volumes that comprise a professional library 
       adequate to permit minimally-competent representation, 
 
     o Those forced to make do with a proprietary law library not 
       favored by the court are stigmatized and condemned to 
       inefficient communication. 
 
     o No person in custody has access to proprietary law libraries 
       that begin to approximate results they might obtain through 
       on-line lookup of data. 
 
     o The legally unskilled, whether novice counsel or pro se 
       litigants, are poorly-served by proprietary citation systems 
       that refer to entire pages, pages which seldom begin with an 
       entire thought, and many not even begin with a full sentence. 
 
     o Counsel, litigants, or judges with vision impairment may not 
       be able to read entire pages that are the units of classical 
       proprietary citation systems, but such persons could easily 
       comprehend an entire paragraph stored as text but quickly 
       convertible to auditory or braille output. 
 
Respectfully submitted, 
 
Eric H. Archer 
Enc.