2024 08 23 Respondent's Brief Pardoe V Salazar

Case No.
B336831
THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT, DIVISION FIVE
Diane Pardoe et. al,

Plaintiffs and Respondents
vs.
Jude Salazar,
Respondent;
Rick Siegel
Intervener/Appellant;
Document received by the CA 2nd District Court of Appeal.

RESPONDENT’S BRIEF
Appeal from An Order of the Los Angeles County Superior Court

Superior Court Case No. 23STCP00683
The Hon. Barbara Meiers, Judge
Jude Salazar
3425 Motor Avenue, Apt 326
Los Angeles, CA 90034
562.294.1810
Respondent In Pro Per
1
CERTIFICATE OF INTERESTED PARTIES
Pursuant to California Rules of Court, rule 8.208(e), the

undersigned Respondent, in pro per, states that the following
persons have some financial or other interest in the outcome of
the proceeding that the party reasonably believes the justices
should consider in determining whether to disqualify themselves
under Canon 3E of the Code of Judicial Ethics. Rick Siegel, Diane
Pardoe, Sarah Pardoe, Jude Salazar.
Dated: August 23, 2024 Respectfully submitted,

/s/ Jude Salazar
Jude Salazar
Respondent In Pro Per
2
TABLE OF CONTENTS
CERTIFICATE OF INTERESTED PARTIES ................................ 2
TABLE OF CONTENTS .................................................................. 3
TABLE OF AUTHORITIES ............................................................ 5
I. INTRODUCTION ..................................................................... 9
II. STANDARD OF REVIEW ...................................................... 13
III. STATEMENT OF THE CASE – PROCEDURE .................... 14
IV. THE PARTIES’ POSITIONS.................................................. 16
A. Summary of the Case ................................................. 16

B. Summary of Argument .............................................. 18

V. LEGAL BACKGROUND ........................................................ 21
A. Purpose of the TAA .................................................... 21

B. History of the TAA .......... ERROR! BOOKMARK NOT
DEFINED.
C. Mechanics of the TAA ................................................ 24
VI. ARGUMENT .......................................................................... 26
A. THE TAA IS NOT UNCONSTITUTIONALLY

VAGUE ....................................................................... 26
1. Appellant’s Challenge: Uncertain as to
Facial or As-Applied ......................................... 26
2. Applicable Standards for Facial Challenge .... 28
3. The TAA Clearly States Who Is Subject to
Regulation Under the TAA. ............................. 29
3
4. The TAA Clearly States What Activity
It Regulates ...................................................... 31
5. The Statute, and Cases Interpreting it,
Provide Ample Notice of the Consequences
for Violation. ..................................................... 33
6. The Absence of Criminal or Civil Penalties
Does Not Make the Talent Agency Act
Toothless ........................................................... 35
7. The Rules of Statutory Construction Do Not
Mandate Any Result Except Avoidance .......... 39
8. The Statute and Case Law Give the
Commissioner Ample Standards to Guide

Her Exercise of Discretion ............................... 45
B. NEITHER THE TAA NOR ITS APPLICATION
VIOLATE THE THIRTEENTH AMENDMENT ...... 46
C. NEITHER THE TAA NOR ITS APPLICATION
VIOLATE THE EXCESSIVE FINES CLAUSE OF
THE 8TH AMENDMENT OF THE US
CONSTITUTION ....................................................... 47
VII. CONCLUSION ..................................................................... 50
4
TABLE OF AUTHORITIES
Cases
Bacall v. Shumway (2021)

61 Cal.App.5th 950.................................................................... 13
BMW of America v. Gore (1995)

517 U.S. 559 .............................................................................. 36
Bob Jones University v. United States (1983)

461 U.S. 574 .............................................................................. 41
Buchwald v. Katz (1972)

8 Cal. 3d 493 .............................................................................. 26
Buchwald v. Superior Court (1967)

254 Cal.App.2d 347 ................................................. 12, 22, 33, 34
Daily v. Bond (9th Cir. 1980)

623 F.2d 624 .............................................................................. 28
Dyna-Med, Inc. v. Fair Employment & Housing Comm. (1987)

43 Cal. 3d 1385 .......................................................................... 36
Foti v. City of Menlo Park (9th Cir.1998)

146 F.3d 629 .............................................................................. 26
Golba v. Dick's Sporting Goods, Inc. (2015)

23 8 Cal. App. 4th 1251............................................................. 50
Grayned v. City of Rockford (1972)

408 U.S. 104 .............................................................................. 28
Holder v. Humanitarian Law Project (2010)

130 S. Ct. 2705 .......................................................................... 28
Hoye v. City of Oakland (9th Cir. 2011)

653 F.3d 835 ........................................................................ 27, 28
Human Life of Washington Inc. v. Brumsickle (9th Cir. 2010)

624 F.3d 990 .............................................................................. 29
Johnson v. Frankell (1997)

520 U.S. 911 .............................................................................. 33
5
Kashani v. Tsann Kuen China Enter. Co. (2004)
118 Cal. App. 4th 531................................................................ 49
Lambert v. California (1957)

355 U.S. 225 .............................................................................. 36
Legal Aid Services of Oregon v. Legal Services Corp (9th Cir.2010)

608 F.3d 1084 ............................................................................ 27
Loving & Evans v. Blick (1949)

33 Cal.2d 603 ............................................................................. 34
Marathon Inc. v. Blasi (2008)

42 Cal. 4th 974 .................................................................. passim
McIntosh v. Mills (2004)

121 Cal. App. 4th 333................................................................ 50
Nat’l Abortion Fed’n v. Gonzales (2d Cir. 2006)

437 F.3d 278 .............................................................................. 28

National Conference of Personal Managers Inc. v. Brown,
2015 WL 4873541 ...................................................................... 47
National Endowment for the Arts v. Finley (1998)

524 U.S. 569 .............................................................................. 28
Park v. Deftones (1999)

71 Cal. App. 4th 1465.......................................................... 22, 31
People v. Cromer (2001)

24 Cal.4th 889 ........................................................................... 13
Pineda v. Williams-Sonoma Stores, Inc. (2011)

51 Cal.4th 524 ........................................................................... 13
Siegel v. Bradstreet,
360 Fed.Appx. 832 (9th Cir. 2009) ................................ 9, 20, 21
Siegel v. Su,
770 Fed.Appx. 877 (9th Cir. 2019 Mem.) ....................... 9, 20, 21
Styers v. Ryan (9th Cir. 2015)

811 F.3d 292,297 ....................................................................... 30
6
Styne v. Stevens (2001)
26 Cal.4th 46 ..................................................................... passim
United States v. Kozminski (1988)

487 U.S. 931 .............................................................................. 46
United States v. Petrillo (1947)

332 U.S. 1 .................................................................................. 29
US v. Evans (1948)
333 U.S. 483 .............................................................................. 36
Village of Hoffman Estates v. Flipside, Hoffman

Estates, Inc. (1982)
455 U.S. 489 .............................................................................. 28
Wachs v. Curry (1993)

13 Cal.App.4th 616............................................................ passim
Waisbren v. Peppercorn Productions, Inc. (1995)

41 Cal.App.4th 246............................................................ passim
Washington State Grange v. Washington State

Republican Party (2008)
552 U.S. 442 .............................................................................. 27
Wicks v. Southern Pac. Co. (9th Cir. 1956)

231 F.2d 130 .............................................................................. 47
Wood v. Krepps (1914)

168 Cal. 382 ................................................................... 12, 33, 37
Yoo v. Robi (2005)

126 Cal. App. 4th 1089 (“California courts have
uniformly held that a contract ... is void ab initio”) .......... 34, 35
Constitutions
Eighth Amendment ............................................................ 17, 27, 47
Thirteenth Amendment ............................................... 17, 27, 46, 47
7
Statutes
Cal. Bus. & Prof. Code § 6125 ....................................................... 49
Cal. Bus. & Prof. Code § 6126 ....................................................... 49
Cal. Bus. & Prof. Code § 7031 ....................................................... 49
Cal. Civ. Code § 1598 ............................................................. passim
Cal. Civ. Code § 1599 ............................................................. passim
Cal. Ins. Code § 15006(b) ............................................................... 49
Cal. Lab. Code § 1700, et seq. (the “Talent Agencies

Act”) ................................................................................. passim
Cal. Lab. Code § 1700.4(a) ............................... 24, 31, 38, 41, 43, 45
Cal. Lab. Code § 1700.5 ................................... 17, 24, 32, 38, 43, 45

Cal. Lab. Code §§ 1700.23 .............................................................. 22
Cal. Lab. Code §§ 1700.25 .............................................................. 22
Cal. Lab. Code §§ 1700.26 .............................................................. 22
Cal. Lab. Code §§ 1700.32 .............................................................. 22
Cal. Lab. Code §§ 1700.33 .............................................................. 22
Cal. Lab. Code §§ 1700.41 .............................................................. 22
Other Authorities
Entertainment Commission Report ...................................... passim
8
I. INTRODUCTION
Unfortunately, this court has been dragged into Appellant
Rick Siegel’s decades-long crusade against the California Talent
Agencies Act, Cal. Lab. Code §1700, et seq. (the “TAA”).1 Not
surprisingly considering Appellant’s history of cases, the appeal
starts with an erroneous position – that because the TAA does
not include a specify for violations of the outright bar against
procurement, neither the Labor Commissioner nor the Courts can
void (in whole, or in part) management contracts for
commissions, or order disgorgement of commissions paid under
such contracts.
The simple reality is that the TAA is remedial in purpose,

and based upon more 150 years of existing law (e.g., Cal. Civ.
Code §1598 and case precedent as to illegal contracts), an illegal
contract is not enforceable. Appellant ignores and distorts the
long history of legal cases supporting this fundamental principle
1 Appellant Rick Siegel was a principal of Marathon

Entertainment of Marathon Entm 't, Inc. v. Blasi (2008) 42 Cal.
4th 974 and a frequent litigant challenging the Act in other cases.
See, e.g., Siegel v. Bradstreet, 360 Fed.Appx. 832 (9th Cir. 2009),
affirming 2008 WL 4195949, *3-4 (C.D. Cal 2008) (unpublished
case rejecting a variety of arguments by Mr. Siegel that
challenged the constitutionality of the Talent Agencies Act,
including due process arguments that the Act fails to provide
notice as to what may be a violation and that the Act does not
specify remedies); see also, Siegel v. Su, 770 Fed.Appx. 877 (9th
Cir. 2019 Mem.), affirming 2018 WL 1393984 (C.D. Cal. 2018)
(again rejecting almost identical arguments that the failure to
specify a remedy renders the Talent Agencies Act
unconstitutional and that it is void for vagueness).
Notably, in this matter, Appellant is an interloper. He
bought the underlying plaintiffs’ claim in order to pursue his
crusade against an unrepresented individual. “Appendix
Document [“Doc.”] 22.
9
that is in no way limited to the TAA. Instead, Appellant seeks to
distort the simple principle that the underlying contract – as an
illegal contract – is unenforceable as matter of law with the
assertion that a remedy was “created” by the Labor
Commissioner. The unenforceability of a contract (and
appropriate severance) – as recognized by Cal. Civ. Code §1598
and 1599 does not constitute a “remedy” but rather a reality as
reflected by this District’s statement with great clarity in
Waisbren v. Peppercorn Productions, Inc. (1995) 41 Cal.App.4th
246, 261-262 (partially overruled by Marathon Entm 't, Inc. v.
Blasi [2008] 42 Cal. 4th 974, 986 ["Marathon"] with respect to the
doctrine of severance) where this District stated:

“Waisbren nevertheless contends that declaring
the parties’ agreement to be void is too severe a
penalty, especially in light of the fact that the Act
does not contain criminal penalties for licensing
violations. We disagree. Nothing in the case law
requires the existence of criminal penalties as a
prerequisite to declaring an illegal contract to be
void. Moreover, the legislative history of the Act
directly contradicts Waisbren’s contention. In
examining the licensing issue, the California
Entertainment Commission specifically addressed
the question of whether criminal sanctions should be
imposed for violations of the Act. (Report at pp. 15-
18.)[2] It recommended that the Legislature not enact
2See Report of the California Entertainment Commission, dated

Dec. 2, 1985, Cal. Doc. E2035 R4 1985. A copy of the report is
available online at the Division of Labor Standards
Enforcement’s website at
https://www.dir.ca.gov/dlse/TAC/California%20Entertainment%2
0Commission%20Report%20-%201985.pdf.
10
criminal penalties, in part because “the most effective
weapon for assuring compliance with the Act is the
power ... to ... declare any contract entered into
between the parties void from the inception.” (Id. at
p. 17.) By following the Commission’s advice and
not enacting criminal penalties, the Legislature
approved the remedy of declaring agreements
void if they violate the Act. Thus, an agreement
that violates the licensing requirement is illegal
and unenforceable despite the lack of criminal
sanctions.
As explained by our Supreme Court: “[T]he

courts generally will not enforce an illegal bargain or
lend their assistance to a party who seeks
compensation for an illegal act. The reason for this

refusal is not that the courts are unaware of possible
injustice between the parties, and that the defendant
may be left in possession of some benefit he should in
good conscience turn over to the plaintiff, but that
this consideration is outweighed by the importance of
deterring illegal conduct. Knowing that they will
receive no help from the courts and must trust
completely to each other’s good faith, the parties are
less likely to enter an illegal arrangement in the first
place.” (Lewis & Queen v. N.M. Ball Sons (1957) 48
Cal.2d 141, 150, 308 P.2d 713.)
Further, it does not matter that some of

Waisbren’s causes of action sounded in tort rather
than contract. “No principle of law is better settled
than that a party to an illegal contract cannot come
into a court of law and ask to have his illegal objects
carried out.... [T]he test [is] whether the plaintiff can
establish his case otherwise than through the
medium of an illegal transaction to which he himself
11
is a party.” (Wong v. Tenneco, Inc. (1985) 39 Cal.3d
126, 135, 216 Cal.Rptr. 412, 702 P.2d 570, citation,
italics, and internal quotation marks omitted; see
also Hydrotech Systems, Ltd. v. Oasis Waterpark
(1991) 52 Cal.3d 988, 997-1002, 277 Cal.Rptr. 517,
803 P.2d 370 [unlicensed contractor cannot sue for
fraud].)”
(Emphasis added.)
Appellant’s primary argument against this long-standing
situation is to reference an erroneous aspect of Wood v. Krepps
(1914) 168 Cal. 382, one of the key cases upon which the 1967
case of Buchwald v. Superior Court (1967) 254 Cal.App.2d 347,
351 relied in holding that an illegal contract could not be

enforced. Appellant ignores the indisputable fact the Supreme
Court in Wood specifically identified two distinct types of
legislative/regulatory schemes and confirmed that where the
provisions are intended simply for the collection of revenue (as in
Wood) the contract is not illegal or void. However, “when the
object of the statute or ordinance in requiring a license for the
privilege of carrying on a certain business is to prevent improper
persons from engaging in that particular business, or is for the
purpose of regulating it for the protection of the public or in the
interest of public morals … a contract made by an unlicensed
person in violation of the statute or ordinance is void.” Id. at 386.
12
Here, there is no dispute that the TAA is a remedial statute
for the protection of artists3 and the existing precedent under the
TAA mandates the affirmation of the trial court’s judgment and
dismissal of the appeal.
II. STANDARD OF REVIEW
Respondent notes that Appellant failed to identify any
standard of review. Considering that the arguments presented by
Appellant focus on the interpretation of the Talent Agencies Act,
Cal. Lab. Code §1700, et seq., and legal standards relating to the
relief ordered by the Superior Court (i.e., voiding the
management agreement on the grounds of illegality and ordering
disgorgement of fees paid under the illegal contract), Respondent

understands that the standard of review in this matter is de
novo.4 E.g., pure questions of law are reviewed de novo. (People
v. Cromer (2001) 24 Cal.4th 889, 894 (pure questions of law are
reviewed de novo); Pineda v. Williams-Sonoma Stores, Inc. (2011)
3 See, Bacall v. Shumway (2021) 61 Cal.App.5th 950, 959-960

(“Appellants concede, however, that the Talent Agencies Act’s
central legislative concern is the exploitation of artists by
representatives. (See Marathon Entertainment, Inc. v. Blasi
(2008) 42 Cal.4th 974, 984, 70 Cal.Rptr.3d 727, 174 P.3d 741
[“Exploitation of artists by representatives has remained the
Act’s central concern through subsequent incarnations to the
present day.”]; Waisbren v. Peppercorn Productions, Inc. (1995) 41
Cal.App.4th 246, 254, 48 Cal.Rptr.2d 437 [the Talent Agencies
Act was enacted for the protection of artists].)”
4 Although Appellant at times challenges the TAA as vague with
respect to the term “procurement,” there is no dispute that the
Plaintiffs in the underlying action repeatedly, and unequivocally,
admit that they “procured.” Doc. 14, AOB, p. 14. Regardless, any
challenge to that term was already determined against
Appellant’s positions in Wachs v. Curry (1993) 13 Cal.App.4th
616, 629.
13
51 Cal.4th 524, 529 (questions of statutory construction are
reviewed de novo).
III. STATEMENT OF THE CASE – PROCEDURE
Plaintiffs Diane Pardoe and Sarah Pardoe filed their
original breach of complaint (22STLC0463) on June 17, 2022
(Appendix Document [“Doc.”] 1). Subsequently, Respondent
Salazar filed a motion to stay with the Superior Court based on
the controlling California Supreme Court precedent, e.g., Styne v.
Stevens (2001) 26 Cal.4th 46 which mandates a stay of the action
where a colorable claim is raised under the TAA because the
California Labor Commissioner had exclusive original
jurisdiction to determine whether Salazar's claims fall within the

scope of the TAA; and if they did, whether Plaintiffs violated the
Act, thus invalidating the alleged written personal management
agreement that formed the gravamen of the original breach of
contract claim. Doc 3.
On October 20, 2022 the Superior Court in 22STLC0463
ruled that the Labor Commissioner did have exclusive
jurisdiction and granted Salazar’s motion to stay pending the
Labor Commissioner’s decision. Doc. 9. Appellant’s arguments
that the Superior Court should have made the initial
determination of whether a colorable claim exists is not
supported by any law. Doc 6.
On February 17, 2023 the Labor Commissioner ruled that
the Plaintiffs had acted as unlicensed talent agents under the Act
and that the management agreement between them and Salazar
14
was void ab initio. They were ordered to disgorge all profits in the
amount of $8,713.74. Doc. 12.
On March 2, 2023, Plaintiffs along with their “non-attorney
representative, Rick Siegel” (now Appellant/Intervener), filed an
appeal of the Labor Commissioner’s decision with the Superior
Court thus creating the case on which this appeal is based --
LASC Case No. 23STCP00683. In an effort to consolidate the
claims, Respondent filed a notice of related cases in both
22STLC0463 and 23STCP00683. On July 28, 2023, Judge Meiers
ordered that 22STLC0463 and 23STCP00683 were related and
that they all be transferred to her so they may be heard in the
same courtroom. Doc. 13.

Despite Appellant’s assertions (AOB, p. 57), a trial de novo
did occur in case no. 23STCP00683 on November 9, 2023. Judge
Meiers gave both Plaintiffs and Respondent the opportunity to be
heard on the merits of the case. She tentatively ruled in favor of
the Respondent but assured both parties that a final order would
be filed with the court. On January 4, 2024 Judge Meiers
affirmed the decision of the Labor Commissioner and entered a
judgment against the Plaintiffs in the sum of $8,713.74 plus
interest at a rate of 10% from February 17, 2023, in the sum of
$726 for a total of $9,439.74. Doc. 23.
Following her decision in 23STCP00683, Judge Meiers held
a hearing in related case 22STLC0463 on January 23, 2024.
Plaintiffs along with Appellant Siegel were given the opportunity
to present an argument on why 22STLC0463 was not barred
under res judicata/collateral estoppel. Specifically, the decision in
15
23STCP00683 was that the Plaintiffs’ conduct violated the Talent
Agencies Action (Cal. Lab. Code §1700, et seq,) and the
agreement was thereby illegal, and hence the breach of contract
case on the same agreement was barred. Plaintiffs were unable to
present valid arguments on the res judicata/collateral estoppel
issues, and Judge Meiers ordered the case dismissed with
prejudice. Doc 27.5
On February 9, 2024, Appellant filed an appeal of case no.
22STLC0463 (the original breach of contract action) which is
pending before the Appellate Division of the Superior Court. By
his own admission via email to Respondents, Appellant
attempted to merge the two related appeals, but was unable to do

so. Appellant has repeatedly attempted to file his brief and
appendix with the Appellate Division of the Superior Court while
simultaneously filing a nearly identical brief in this case.
Thereby affording himself the opportunity to have the same
argument heard, concurrently, by two different courtrooms.
IV. THE PARTIES’ POSITIONS
A. Summary of the Case
This matter arises out of a contract dispute between
Plaintiffs and Respondent based on a former talent management
relationship. Plaintiffs have already admitted to illegally
procuring work without a license but paradoxically argue that
California’s Talent Agencies Act (“TAA”) is “facially”
5The copy attached to the Appendix is incomplete. For the

court’s convenience, Respondent has filed a Supplemental
Appendix with the missing documents.
16
unconstitutional and that the California courts which have
interpreted the TAA are wrong. AOB, p. 17.
The TAA provides that “[n]o person shall engage in or carry
on the occupation of a talent agency without first procuring a
license therefore from the Labor Commissioner.” Cal. Lab. Code §
1700.5. Section 1700.4 defines a “[t]alent agency” as “a person or
corporation who engages in the occupation of procuring, offering,
promising, or attempting to procure employment or engagements
for an artist or artists . . . .”
Appellant here challenges the constitutionally of the TAA
on several grounds: Appellant erroneously asserts that (1) the
TAA is unconstitutionally vague on its face and as applied

because it does clarify who is being regulated and that in the
absence of a penalty provision, the contract cannot be declared
void, (2) that it results in involuntary servitude because personal
managers whose contracts are affected may not be properly
compensated for their services in violation of the Thirteenth
Amendment, (3) that as applied the TAA violates the Excessive
Fines Clause of the 8th Amendment, and (4) that the Labor
Commissioner and all courts that have dealt with the TAA over
the past 50+ years knowingly and inexplicably ignored rules of
statutory construction.
Appellant seeks judicial declaration that the TAA is
unconstitutional on its face and as applied. AOB, p. 59.
Respondent contends that this appeal is not well taken and is
premised on either misunderstandings of the law and the cases
17
decided over the past 50+ years, or outright distortions of the
operative law.
B. Summary of Argument
Appellant makes a facial and as applied challenge to a
statutory scheme that has been validly applied for more than 25
years, including by California’s highest court.
The TAA is not unconstitutionally vague simply because
the Legislature adopted a framework that delegates the initial
determination of factual disputes to the Commissioner. The
statutory scheme clearly prohibits unlicensed persons from
procuring employment for artists, and leaves it to the
Commissioner and the courts and to determine whether

particular conduct constitutes “procurement.”
Appellant’s primary attack is on the way California courts
and the Commissioner have remedied violations of the TAA. That
is, when a personal manager has been shown to have “procured
employment” for an “artist” without a license, the artist may
avoid, partially or completely, the personal manager’s contract on
the grounds that it violates the public policy articulated in the
TAA.
Appellant incorrectly argues that the Commissioner has
invented this remedy without a statutory basis, and asserts that
the Commissioner adjudicates peoples’ rights. But this “remedy”
is a straightforward application of common law set forth in cases
for more than a century and the California Civil Code provisions
enacted in 1872, Section 1598 and 1599, that voids (in whole or in
part) contracts whose object is unlawful. As discussed below, the
18
applicability of this rule to personal managers’ contracts has been
affirmed by the California Supreme Court and every court of
appeal to consider the issue.
Appellant argues that because the TAA itself does not
provide a remedy for violation of its licensing requirement,
persons not in the “occupation of talent agent” (i.e., unlicensed
personal managers) are free to ignore it. But the absence of
criminal or civil penalties does not make the TAA toothless. In
enacting the TAA, the California Legislature wisely authorized
the Commissioner to resolve what are inherently fact-specific
controversies, and apply statutory concepts to complex situations
arising in a specialized industry. The Commissioner, with the

help of the courts, has developed a specialized body of law that
provides ample notice and guidance to professional personal
managers. The Legislature also built extraordinary due process
protections into the TAA, by giving original jurisdiction of TAA
related disputes to the Commissioner, but then providing a trial
de novo in the superior court for anyone aggrieved by a decision
of the Commissioner. Likewise, the Commissioner’s decisions are
not enforceable, except upon petition to the superior court.
This is not the first time that these flawed arguments have
been used to fight the constitutionality of the TAA. This is an
argument all too familiar to Appellant, who has not only
purchased the opportunity to be the Appellant in this case but
acted as the “non-attorney” representative and “expert” for the
Plaintiffs in the many filings and responses filed with the Labor
Commissioner’s office. Doc 4 and 22.
19
Appellant is no stranger to this court at both the state and
federal level and has managed to use this case as an opportunity
to resurface arguments he brought against the Labor
Commissioner, in 2008 and 2018. Both of his cases were
dismissed with prejudice. See, e.g., Siegel v. Bradstreet, 360
Fed.Appx. 832 (9th Cir. 2009), affirming 2008 WL 4195949, *3-4
(C.D. Cal. 2008) (unpublished case rejecting a variety of
arguments by Mr. Siegel that challenged the constitutionality of
the Talent Agencies Act, including due process arguments that
the Act fails to provide notice as to what may be a violation and
that the Act does not specify remedies); see also, Siegel v. Su, 770
Fed.Appx. 877 (9th Cir. 2019 Mem.), affirming 2018 WL 1393984

(C.D. Cal. 2018) (again rejecting almost identical arguments that
the failure to specify a remedy renders the Talent Agencies Act
unconstitutional and that it is void for vagueness).
Now that same litigant has decided to bring these claims in
a different court room, using the Plaintiffs as a straw man in an
attempt to turn the Respondent into an example and use this
case as a, “watershed moment for the entertainment industry.”
Doc, 12, p. 150, ¶ 3.
Despite Appellant’s attempts to change the headings,
formation of arguments, and introduce more irrelevant case law
in hopes it will confuse both the Respondent and this Court, the
result should be the same as it was 6 years ago. The TAA is
constitutional as the Labor Commissioner demonstrated in 2008
and 2018 when these claims were originally raised.
20
As Appellant did before, he once again attempts to sidestep
the line of governing California cases construing the TAA, and
urges this Court instead to focus only on the text of the statute
and authorities that have nothing to do with the TAA, and then
conduct his own de novo interpretation of California law.
Compare, Siegel v. Bradstreet, 360 Fed.Appx. 832 (9th Cir. 2009),
affirming 2008 WL 4195949, *3-4 (C.D. Cal 2008); see also, Siegel
v. Su, 770 Fed.Appx. 877 (9th Cir. 2019 Mem.), affirming 2018
WL 1393984 (C.D. Cal. 2018). 6
V. LEGAL BACKGROUND
A. Purpose of the TAA
As recently as 2009, the California Legislature reaffirmed

the need for the TAA, finding that talent agency contracts in the
entertainment industry too often “have worked a fraud, deceit,
imposition, and financial hardship upon the people of this state,
particularly upon children and other minors . . . [and] the talent
industry has a significant impact upon the economy and well-
being of this state.” § 1701, Historical and Statutory Notes, 2011
Main Volume Stats. 2009, c. 286 (A.B.1319). Accordingly, the
TAA is “necessary for the public welfare.” Id. To confront this
problem, the Legislature declared that:
[T]he purpose of this act is to safeguard the public
against fraud, deceit, imposition, and financial
hardship, and to foster and encourage competition,
fair dealing, and prosperity in the field of talent
6Respondent shares Appellant’s unpublished cases to show that

Appellant has been pursuing these arguments for the past 15
years. See also, Marathon Entm't, Inc. v. Fox & Spillane,
Cal.Rptr.3d, affirming 2011 WL 4357854 (Cal. Ct. App 2011).
21
services by prohibiting or restricting false or
misleading advertising and other unfair, dishonest,
deceptive, destructive, unscrupulous, and fraudulent
business practices by which the public has been
injured in connection with talent services.
Id.
The stated purpose of the Act is remedial. For example, an
agent must have his form of contract approved by the Labor
Commissioner, maintain his client’s funds in a trust fund
account, record and retain certain information about his client,
refrain from giving false information to an artist concerning
potential employment, and refrain from sending talent to
dangerous places. See Cal. Lab. Code §§ 1700.23, 1700.25,

1700.26, 1700.32, 1700.33 and 1700.41.) “Because the Act is
remedial, it should be liberally construed to promote its general
object.” Park v. Deftones, (1999) 71 Cal. App. 4th 1465, 1471-
1472, citing Buchwald v. Superior Court, (1967) 254 Cal. App. 2d
347, 354.
B. History of the TAA
Roots of the TAA trace back to 1913, when the state
legislature first enacted the Employment Agencies Act (EAA).
Since 1943, it has regulated any talent agent (then called “artist
manager”) who “engages in the occupation of advising,
counseling, or directing artists on the development of their
professional careers and who procures, offers, or promises
employments or engagements of an artist. . . .” 1943 Cal. Stat.
1326 (ch. 329) (emphasis added). See Report of the California
Entertainment Commission, dated Dec. 2, 1985, Cal. Doc. E2035
22
R4 1985, p. 36.4.7 In 1978, the Legislature considered, but opted
not to establish, a separate licensing scheme for personal
managers, but did change the statute’s name from the Artists’
Managers Act to the Talent Agencies Act. Marathon, 42 Cal. 4th
at 984-85. 8
In 1982, the Legislature provisionally amended the TAA to
add a one- year statute of limitations, eliminate criminal
sanctions, and establish a “safe harbor” for managers to procure
employment if they collaborated with a licensed agent. Marathon,
42 Cal. 4th at 985. The Legislature also established a 10-member
California Entertainment Commission (the “Entertainment
Commission”), including three each of agents, managers and

artists, plus the Commissioner. Its task was to evaluate the Act,
consider whether to retain the provisional amendments, and
“recommend to the Legislature a model bill.” Id. After numerous
meetings and hearings over many months, the Entertainment
Commission submitted its report and recommendations on
December 2, 1985. See Entertainment Com. Rep., pp. 1-2.
In 1986, the Legislature adopted a bill that implemented
the Entertainment Commission’s recommendations (set out at
7 A copy of the report is available online at the Division of Labor

Standards Enforcement’s website at
https://www.dir.ca.gov/dlse/TAC/California%20Entertainment%2
0Commission%20Report%20-%201985.pdf.
8 The 1978 amendments adopted what is substantially the
present definition of Talent Agent: “A talent agency is hereby
defined to be a person or corporation who engages in the
occupation of procuring, offering, promising, or attempting to
procure employment or engagements for an artist or artists.
Talent agencies may, in addition, counsel, or direct artists in the
development of their professional careers.” Id. at p. 36.
23
Entertainment Com. Rep., pp. 22–34). Marathon at 985. The TAA
has remained largely unchanged ever since. Id.
C. Mechanics of the TAA
The TAA defines what a talent agency is by describing the
scope of the activities (§1700.4) and declares that no person shall
engage those activities without a license (§1700.5). The TAA’s
definition of a talent agency narrowly focuses on conduct
intended to secure professional “employment or engagements” for
an “artist or artists.” § 1700.4(a). “Thus, it does not cover other
services for which artists often contract, such as personal and
career management (i.e., advice, direction, coordination, and
oversight with respect to an artist’s career or personal or

financial affairs) [citations], nor does it govern assistance in an
artist’s business transactions other than professional
employment.” Styne v. Stevens, (2001) 26 Cal. 4th 42, 51.
Likewise, the TAA permits talent agents to perform
services for which a license is not required. § 1700.4 [“Talent
agencies may, in addition, counsel or direct artists in the
development of their professional careers.”]
Because the TAA regulates the procurement of employment
for artists, it governs such conduct regardless of how the procurer
labels their services:
The [TAA] establishes its scope through a functional,
not a titular, definition. It regulates conduct, not
labels; it is the act of procuring (or soliciting), not the
title of one’s business, that qualifies one as a talent
agency and subjects one to the Act’s licensure and
related requirements. (§ 1700.4, subd.(a).) Any person
who procures employment—any individual, any
24
corporation, any manager—is a talent agency subject
to regulation. (§§ 1700, 1700.4, subd. (a).)
Consequently, as the Courts of Appeal have
unanimously held, a personal manager who solicits or
procures employment for his artist-client is subject to
and must abide by the Act.
Marathon, 42 Cal. 4th at 986 (original emphasis).

The TAA authorizes the Commissioner to license talent
agencies, so she does not directly regulate personal managers as
such. Still, a personal manager may come within the
Commissioner’s jurisdiction if he or she makes a disputed claim
for fees and the artist establishes a colorable claim that the
disputed contract is within the TAA. § 1700.44(a); Styne, 26 Cal.

4th at 54-56, and n.6. Then, the Commissioner’s authority is
limited to hearing and determining the TAA-related dispute
between artist and manager, or else certifying that there is no
controversy. § 1700.44(a).9 The TAA gives the Commissioner
original and exclusive jurisdiction over issues arising under its
9 Appellant erroneously asserts the Superior Court erred in the

first instance in this matter by finding a “colorable” claim when
there was no statutorily prescribed penalty. As should be clear,
from Styne, once a colorable claim is asserted, the Labor
Commissioner has the original exclusive jurisdiction and the
absence of a prescribed remedy is irrelevant. Styne, 26 Cal.4th,
at 49-50, fn. 10. (“Adhering to this principle, we use the term
“colorable” in its broadest sense. Certainly the superior court
need not refer to the Commissioner a case which, despite a
party's contrary claim, clearly has nothing to do with the Act. For
example, an automobile collision suit between persons
unconnected to the entertainment industry is manifestly not a
controversy arising under the Act, and it cannot be made one by
mere utterance of words. On the other hand, if a dispute in which
the Act is invoked plausibly pertains to the subject matter of the
Act, the dispute should be submitted to the Commissioner for
first resolution of both jurisdictional and merits issues, as
appropriate.”
25
provisions. Marathon, 42 Cal. 4th at 981 (citing Styne v. Stevens,
supra, 26 Cal. 4th at 54–56 and § 1700.44(a)). But the
Commissioner’s determinations are not final; either party may appeal
to the superior court within 10 days. § 1700.44(a). If no trial de novo
is requested (or is requested but no bond is posted), the prevailing
party may petition to confirm the Commissioner’s award and enforce
the resulting judgment. Buchwald v. Katz, (1972) 8 Cal. 3d 493, 500.
The appealing party is entitled to a de novo hearing in the
superior court, not simply a review of the Commissioner’s
proceedings. Id. at 498. Still, in the de novo trial parties can and do
rely on evidence, testimony and pleadings presented in the
Commissioner’s hearing. Id.; see also Marathon, 42 Cal. 4th at 982.

VI. ARGUMENT
A. THE TAA IS NOT UNCONSTITUTIONALLY
VAGUE
1. Appellant’s Challenge: Uncertain as to Facial
or As-Applied
Appellant’s brief is muddled on whether it challenges the
TAA on its face or as applied to personal managers. He seems to
attempt both approaches, but never really articulates either one.
Further, Appellant fails to make a persuasive case under any
analytical approach.
Generally speaking, a facial challenge attacks an entire
legislative enactment or provision. See Foti v. City of Menlo Park,
(9th Cir.1998) 146 F.3d 629, 635 (statute is facially
unconstitutional if “it is unconstitutional in every conceivable
application, or it seeks to prohibit such a broad range of protected
26
conduct that it is unconstitutionally overbroad”). The present
complaint seeks this sweeping relief against the entire TAA.
AOB, p. 59. Where the complaint does not charge statutory
overbreadth, “a facial challenge must fail where the statute has a
plainly legitimate sweep.” Washington State Grange v.
Washington State Republican Party, (2008) 552 U.S. 442, 449.
In contrast, the typical as-applied attack challenges only
one of the rules in a statute, a subset of the statute’s applications,
or the application of the statute to a specific factual circumstance,
under the assumption that a court can “separate valid from
invalid subrules or applications.” Hoye v. City of Oakland, (9th
Cir. 2011) 653 F.3d 835, 857, quoting Richard H. Fallon, Jr., As-

Applied and Facial Challenges and Third–Party Standing, (2000)
113 Harv.L.Rev. 1321, 1334. At least one of Appellant’s
arguments invokes this theory, contending that enforcement of
the TAA violates the Thirteenth Amendment and Excessive
Penalties Clause of the 8th Amendment rights of Plaintiff and its
members, as applied. AOB, p. 9. But here again, Appellant seeks
to enjoin the entire statute, praying “this Court should give
declarative and injunctive relief, finding that the TAA is
unconstitutional on its face and as applied.” AOB, p. 59.
Since Appellant does not show that the statute is
unconstitutional on its face or as-applied, the court may not need
to resolve which type of challenge is being made here. The two
types of challenge “differ in the extent to which the invalidity of a
statute need be demonstrated.” Legal Aid Services of Oregon v. Legal
Services Corp, (9th Cir.2010) 608 F.3d 1084, 1096. “Because the
27
difference between an as-applied and a facial challenge lies only
in whether all or only some of the statute’s subrules (or fact-
specific applications) are being challenged, the substantive legal
tests used in the two challenges are ‘invariant.’” Hoye, supra, 653
F.3d at 857–858., quoting Legal Aid Services of Oregon, supra, 608
F.3d at 1096. In other words, how one must demonstrate the
statute’s invalidity remains the same for both types of challenges,
namely, by showing that a specific rule of law, usually a
constitutional rule of law, invalidates the statute, whether in a
personal application or to all. See Nat’l Abortion Fed’n v. Gonzales,
(2d Cir. 2006) 437 F.3d 278, 293-94.
2. Applicable Standards for Facial Challenge

The plaintiff who asserts a facial challenge on
constitutional vagueness grounds bears a heavy burden. National
Endowment for the Arts v. Finley, (1998) 524 U.S. 569, 580,
(“[f]acial invalidation ‘is, manifestly, strong medicine’ that ‘has
been employed by the Court sparingly and only as a last resort’”)
(internal citations omitted). On a facial challenge, where First
Amendment rights are not implicated, a statute should be upheld
unless it is “impermissibly vague in all of its applications.”
Village of Hoffman Estates v. Flipside, Hoffman Estates, Inc.,
(1982) 455 U.S. 489, 494-495. A facial challenge charges that the
law is incapable of any valid application. Id.
A law is not unconstitutionally vague if it provides a
“person of ordinary intelligence a reasonable opportunity to know
what is prohibited, so that he may act accordingly.” Grayned v.
City of Rockford, (1972) 408 U.S. 104, 108; see also Daily v. Bond,
28
(9th Cir. 1980) 623 F.2d 624, 626 (statute is not
unconstitutionally vague if it gives fair warning of the proscribed
conduct). A statute may be found to be unconstitutional if it “is so
standardless that it authorizes or encourages seriously
discriminatory enforcement.” Holder v. Humanitarian Law
Project, (2010) 130 S. Ct. 2705, 2718 (quoting United States v.
Williams, (2008) 553 U.S. 285, 304). But the Due Process Clause,
under which a vagueness challenge falls, does not present an
“insuperable obstacle to legislation” by demanding impossible
standards of precision for criminal laws. United States v. Petrillo,
(1947) 332 U.S. 1, 7; see also Holder, 130 S. Ct. at 2719 (“We have
said that when a statute ‘interferes with the right of free speech

or of association, a more stringent vagueness test should apply. . .
. But ‘perfect clarity and precise guidance have never been
required even of regulations that restrict expressive activity’”)
(internal citations omitted). “‘When Congress does not define a
term in a statute, we construe that term according to its
ordinary, contemporary, common meaning.’” Human Life of
Washington Inc. v. Brumsickle, (9th Cir. 2010) 624 F.3d 990, 1021
(quoting United States v. Kilbride, (9th Cir. 2009) 584 F.3d 1240,
1257).
3. The TAA Clearly States Who Is Subject to
Regulation Under the TAA.
It is clear that the TAA regulates those who procure
employment for artists, as opposed to persons who happen have a
certain job title. Marathon Entm 't, Inc. v. Blasi, (2008) 42 Cal.
4th 974, 986 ("Marathon") [the TAA "regulates conduct, not
29
labels"]). Appellant argues that it there is clear intent on the part
of the legislature to regulate managers and that the California
Supreme Court’s “holding is wrong” and urges a different reading
of state law. Doc. 4. But even if this Court were inclined to agree
with Appellants’ interpretation of state law, it is “constrained to
defer to the highest state court on a matter of state law and may
not construe [state law] differently than did the [state] Supreme
Court.” Styers v. Ryan, (9th Cir. 2015) 811 F.3d 292,297 n.5.
Marathon and Styne make clear that, as a matter of California
law, the TAA “establishes its scope through a functional, not a
titular, definition. Marathon, 42 Cal. 4th at 986.
The California Supreme Court in Marathon, was in fact

responding to this Appellant who was making the same
argument that he repeats here. The California Supreme Court
determined that personal managers are not exempt from the
reach of the TAA just because they call themselves “personal
managers.” Rather, “they remain exempt from regulation insofar
as they do things that personal managers do, but they are
regulated under the Act to the extent they stray into doing the
things that make one a talent agency under the Act.” Marathon,
42 Cal. 4th at 19 989. Through Plaintiffs’ own admission their
various actions into procurement made them a talent agency
under the Act and therefore subject to regulation. AOB, p.14; see
also Docs. 14-15. The California Supreme Court has already
rejected Appellants interpretation of state law, now adopted by
Plaintiffs, and this Court must too.
30
4. The TAA Clearly States What Activity It
Regulates
The Act, remedial in nature, provides that only licensed
talent agents -- and not unlicensed managers such as Plaintiffs --
can perform the services of talent agents, which are defined as
"procuring, offering, promising, or attempting to procure
employment or engagements for an artist . . . ." See Cal. Lab.
Code §§1700.4(a) [defining what constitutes a talent agency],
1700.5 [setting forth basic licensing requirement for all persons
who engage in the conduct of a talent agent]; Park v. Deftones,
(1999) 71 Cal.App.4th 1465, 1469-1471; Waisbren v. Peppercorn
Productions, Inc., (1995) 41 Cal.App.4th 246, 252-255. Thus,

under the Act, neither a manager (nor anybody else who is not
licensed as a talent agent) may procure or attempt to procure
employment or engagements for an artist. Id.
The term “procure,” as used in this statute, means to get
possession of: obtain, acquire, to cause to happen or be done:
bring about.” Wachs v. Curry, (1993) 13 Cal.App.4th 616, 628,
abrogated on other grounds as recognized by Marathon, 42 Cal.
4th at 987. Thus “procuring employment” under that statute
includes attempting to attain employment on behalf of an artist,
negotiating for employment, sending an artist’s work to
prospective employers and entering into discussions regarding
employment contractual terms with a prospective employer.
Appellant contends that the Legislature has never enacted
an express provision reserving the activity of procuring
employment for an artist. AOB, p. 7. That statement is
31
misguided. Labor Code section 1700.5 expressly provides that
“[n]o person shall engage in or carry on the occupation of a talent
agency without first procuring a license therefore from the Labor
Commissioner.” That simple phrase cannot be interpreted other
than as exclusively reserving procurement activity to licensed
talent agents. See, Marathon, 42 Cal. 4th at 986.
In contrast, a person may counsel and direct artists in the
development of their professional careers, other otherwise
“manage” artists – while avoiding any procurement activity
(procuring, promising, offering, attempting to procure artistic
employment of engagements) – without the need for a talent
agency license. In addition, such person may procure non artistic

employment or engagements for the artists, without the need for
a license. Styne v. Stevens, (2001) 26 Cal. 4th 42.
Appellant argues that requiring an unlicensed person to
defend itself at the Labor Commission for helping their client get
work, the very reason they were hired, is unconstitutional as
applied. Doc 4. However, that conclusory statement has no actual
legal basis. As other courts have recognized, the concept of
“procuring” is readily understandable in the context of California
law. Wachs v. Curry, (1993) 13 Cal. App. 4th 616, 629. Even if the
Labor Commissioner and the California courts may not have
reached a perfectly uniform approach to analyzing the TAA, the
lack of perfect clarity and precise guidance is not sufficient basis
for declaring the provisions unconstitutionally vague. Regardless,
as reflected in the Appendix, there was never any dispute that
32
the Plaintiffs (i.e., the Pardoes) “procured” work as they admitted
the fact.
5. The Statute, and Cases Interpreting it, Provide
Ample Notice of the Consequences for
Violation.
It is clear that the consequences for violating the TAA are
contract illegality and voidness. Appellant contends that the
Legislature has never enacted an express penalty for doing so
without a license. AOB, p. 7. But what the Appellant does is ask
the Court to ignore one of the most fundamental tenets of the law
– that the Courts will not enforce illegal contracts – as well as
decades of precedent applying that principle. For example,

Appellant repeatedly attacks Buchwald v. Superior Court, (1967)
254 Cal. App. 2d 347 as wrongly applying Wood v. Krepps, (1914)
168 Cal. 382. AOB, p. 53-54. When it is the Appellant who either
deliberately or erroneously recognizes the clear and unequivocal
statement in Wood indicating that where a legislative scheme
exists for the protection of the public instead of for the collection
of revenue, the violation of that scheme renders the parties’
agreement void. Wood v. Krepps, (1914) 168 Cal. 382, 386.
Regardless, this Court cannot ignore the California courts’
interpretation of California law. See Johnson v. Frankell, (1997)
520 U.S. 911, 916; supra, Section I(B)(l). And California law is
crystal clear: "[A]n unlicensed person's contract with an artist to
provide the services of a talent agency is illegal and void." Styne
v. Stevens, (Cal. 2001) 26 P.3d 343, 349; see id. at 352 ("the
Commissioner may declare the contract void"); Marathon, 42 Cal.
33
4th at 992 n.11 (approving Styne), 994 ("the Labor Commissioner
has the 'power' to void contracts"); Yoo v. Robi, (2005) 126 Cal.
App. 4th 1089, 1103 ("California courts have uniformly held that
a contract ... is void ab initio"); Waisbren v. Peppercorn Prods.,
Inc., (1995) 41 Cal. App. 4th 246, 261; Buchwald v. Superior
Court, (1967) 254 Cal. App. 2d 347, 351 (1967).10
Contrary to Appellant’s contention, the Labor
Commissioner is not prescribing a penalty beyond what the
legislature prescribed. AOB, p. 42. It is simply finding the
contract is unenforceable based upon illegality. These findings
should be considered in the context that earlier versions of the
TAA included a criminal sanction, but the Legislature removed it

because it found that the sanction of contract voidness was the
proper remedy for a violation of the TAA. See Waisbren, 41 Cal.
App. 4th at 261-62) and Ent. Comm. Rep. By allowing the
criminal sanction to lapse in response to the Commission Report,
the Legislature “approved the remedy of declaring agreements
void if they violate the Act. Thus, an agreement that violates the
10Appellant’s references to Loving & Evans v. Blick, (1949) 33

Cal.2d 603, are similarly misplaced. In Loving, the court voided
contracts that were unlawful because of a licensing statute
enacted to protect the public. However, no actual penalty is
specified; rather, the licensing scheme simply required licensing
or the conduct was illegal. Appellant erroneously derives his own
rule that a contract cannot be illegal and void unless the
Legislature has prescribed a cumulative sanction in the licensing
statute. But Loving & Evans is a subset of the general rule of
contract voidness, not a limitation on it. Nothing in Loving &
Evans, or any other case limits the general rule to situations in
which the Legislature imposes cumulative criminal sanction. On
the contrary, under California Law, a contract can be illegal
under numerous provision of the Civil Code governing contract
law, whether or not a cumulative sanction is present.
34
licensing requirements is illegal and unenforceable despite the
lack of criminal sanctions.” Waisbren, 41 Cal. App. 4th at 262; see
Yoo, 126 Cal. App. 4th at 1104. This long-standing interpretation
of the TAA is no mystery, especially to a sophisticated repeat
player like Appellant.
6. The Absence of Criminal or Civil Penalties
Does Not Make the Talent Agency Act
Toothless
Appellant argues that “as the TAA has no prohibitionary
statute or penalty provision…it is clear the Act as it has been
enforced against Appellants and others is extrajudicial and
unconstitutional.” AOB, p. 38, ¶ 2. By Appellant’s reasoning,

because the TAA contains no penalties, it can be ignored with
impunity. But this would thwart the TAA’s remedial purpose, “to
protect artists seeking professional employment from the abuses
of talent agencies.” Styne v. Stevens, supra, 26 Cal. 4th at 50, 51;
see also Marathon, 42 Cal. 4th at 984. As already noted, when the
Legislature decided to eliminate criminal sanctions from the
TAA, it left untouched the existing civil remedy of contract
avoidance and the administrative mechanism that governs how
and when it is applied. See Waisbren, 41 Cal. App. 4th at 261-62)
and Ent. Comm, Rep.
35
The fact that the artist’s remedy may operate to the
detriment of an unlicensed manager does not transform that
remedy into a penalty, criminal or otherwise.11
Appellant also argues that the Commissioner has created a
remedy that the Legislature withheld. AOB, p. 28, ¶ 1, citing
Dyna-Med, Inc. v. Fair Employment & Housing Comm., (1987) 43
Cal. 3d 1385, 1388. However, in sharp contrast to the simple
declaration that the management contract is illegal,
unenforceable and supports disgorgement as to commissions, in
Dyna-Med, Inc., the Fair Employment and Housing Commission
imposed punitive damages against an employer without
statutory authority. The California Supreme Court found that

the purpose of the FEHA was to provide effective remedies to
eliminate discrimination, and as such the statutorily authorized
remedies were exclusively corrective and equitable in nature,
designed to make employee whole. “Punitive damages, by
contrast, are neither equitable nor corrective; punitive damages
11 Appellant’s authorities on this point (AOB, p. 33-35, 39) are

irrelevant because they all concern the creation of crimes and
penalties imposed by government action. See Lambert v.
California, (1957) 355 U.S. 225, 227-28 [due process forbids
penalizing felon for failure to register where felon had no actual
knowledge of duty and failure not willful]; BMW of America v.
Gore, (1995) 517 U.S. 559, 574 [punitive damage case, due
process requires notice both of forbidden conduct and of penalty
state may impose]; US v. Evans, (1948) 333 U.S. 483, 495
[language of criminal statute too ambiguous for court to resolve
uncertainty as nature of several proscribed acts and penalty
assigned to each]. BMW of America, supra, actually undermines
appellant’s argument. “The strict constitutional safeguards
afforded to criminal defendants are not applicable to civil cases,
but the basic protection against ‘judgments without notice’
afforded by the Due Process Clause is implicated by civil
penalties.” Id. at n.22, original emphasis.
36
serve but one purpose—to punish and through punishment, to
deter.” 43 Cal. 3d at 1387–1388. Therefore, the imposition of
punitive damages without specific statutory authority was
unsupported and was not a recognized corollary for the purported
improper conduct. Here, avoidance of an illegal contract is not
punitive, it is simply a matter of how the law works.
Moreover, avoidance is purely remedial and neither
punitive nor compensatory. Also, the civil remedy of contract
avoidance is not the invention of the Commissioner, but the
consequence of the ancient rule that courts will not enforce an
illegal contract. (e.g., Wood v. Krepps, (1914) 168 Cal. 382, 386).
This is recognized by the California Supreme Court in Marathon

which notes that while the TAA contains no remedy for illegal
procurement, California Civil Code sections 1598 and 1599 –
enacted in 1872 as codification of recognized legal principles -- do.
42 Cal. 4th at 991. Section 1599 provides, “Where a contract has
several distinct objects, of which one at least is lawful, and one at
least is unlawful, in whole or in part, the contract is void as to the
latter and valid as to the rest.” Cal. Civ. Code § 1599 (emphasis
added).12
Applying ordinary rules of statutory interpretation,
Marathon construed § 1599 and the TAA so as to effectuate both.
Id. It concluded that the two are not in conflict; indeed the Civil
Code provides the remedy the TAA lacks. The Act defines conduct
12The Marathon court went on to recognize that: “Civil Code

section 1598 codifies the companion principle for when
severability is infeasible[.]” Id. at 991, fn. 9.
37
and limits those who can engage in such conduct; the result is
that contractual arrangements in violation are illegal. Cal. Lab.
Code §§1700.4(a) and 1700.5.
The cases that Appellant cites fail to give any support to its
position. For example, in Dyna-Med, Inc. v. Fair Employment &
Housing Com the Fair Employment and Housing Commission
imposed punitive damages against an employer. The California
Supreme Court held that the purpose of the FEHA is to provide
effective remedies to eliminate discrimination, and noted that the
statutorily authorized remedies were exclusively corrective and
equitable in nature, designed to make employee whole. “Punitive
damages, by contrast, are neither equitable nor corrective;

punitive damages serve but one purpose—to punish and through
punishment, to deter.” (43 Cal. 3d at 1387–1388). The Court
concluded that the Commission had exceeded its authority. Id.
Here, avoidance of an illegal contract is not punitive, it is
remedial, and therefore well within the authority delegated to the
Commissioner by the Legislature.
In sum, the consequence for acting as an unlicensed talent
agent is a creature of common law as reflected by the 1872 Civil
Code and the TAA, not administrative fiat. Non-enforcement of
an illegal contract is not a punishment imposed by the
Commissioner or even a “remedy” in any traditional sense; it is a
recognition that an illegal contract cannot be enforced through
the courts.
38
7. The Rules of Statutory Construction Do Not
Mandate Any Result Except Avoidance
Appellant attacks the entire TAA and states that by
accepting, adjudicating and ruling on petitions for controversy
against “managers,” the Labor Commissioner and all involved
knowingly and inexplicably ignore a multitude of rules of
statutory construction. AOB, p. 9. In support, Appellant provides
a list of rules he believes have been violated all entirely based on
his inexcusable misinterpretation of the TAA.
Respondent hereby attempts to clarify and answer each of
Appellant’s continued false contentions and misinterpretation of
statutory construction rules as follows:

Rule 1: “The law should be given its plain meaning
wherever possible.” U.S.C Rules of Statutory Construction and
Interpretation, rule 1. Appellant argues that the TAA violates
Rule 1 of statutory construction because it has no clarity as to
whether procurement is regulated and how its enforced. AOB, p.
27, ¶ 1. However, as demonstrated above, it is clear that
procurement is reserved for licensees and that the consequence is
contract voidance.
Rule 2: “Statutes must be ‘entirely harmonious with all
laws as a whole.” U.S.C Rules of Statutory Construction and
Rule 2 because the CLC’s enforcement of the TAA is anomalous
as to how all other licensing schemes are interpreted. AOB, p. 28,
¶ 3. This argument is irrelevant as licensing schemes differ, and
39
however other licensing schemes are structured, the Legislature
clearly intended that contracts made in violation of the TAA be
void.
Rule 3: “Every word within a statute is there for a purpose
and should be given its due significance.” U.S.C Rules of
Statutory Construction and Interpretation, rule 3. Appellant
quotes this rule in his brief but provides no argument as to why
he feels the TAA violates it. AOB, p. 25, ¶ 3. Regardless, consider
the text of both Cal. Lab. Code §§1700.4 and 1700.5, only a
licensed agent can procure and procurement in violation of the
statute renders the conduct (and contract) illegal.

Rule 4: “All laws are to be interpreted with the legislative
intent for which they were originally enacted…the passage of no
amount of time can change the original legislative intent of a
law.” U.S.C Rules of Statutory Construction and Interpretation,
rule 4. Appellant selectively picks a portion of this rule and
argues that the TAA violates it because the history of the TAA
makes it inarguably clear that the legislature never had an
interest in requiring managers to have a license to procure. AOB,
p. 32, ¶ 1. The TAA has always had clear legislative intent and
purpose, protect artists from abuse of all who engage in
unlicensed procurement, not just managers. Styne v. Stevens
supra, 26 Cal. 4th at 50, 51; see also Marathon, 42 Cal. 4th at 984.
40
Rule 5: “Presumption may not be used in determining a
statute.” U.S.C Rules of Statutory Construction and
Rule 5 because the Act is unclear as to whether procurement is
reserved for licensees and that managers are subject to
regulation. AOB, p. 32, ¶ 2. Once again, the act is clear that
procurement is reserved for licensees and that all persons who
procure employment without a license are subject to regulation.
Rule 6: “The proper audience to turn to in order to deduce
the meaning of a statute are the persons who are subject of the
law, and not a judge.” U.S.C Rules of Statutory Construction and

Rule 6 because §1700.4 (a) lists three defining activities of talent
agencies but neither it or any statute expressly states that those
activities are reserved for licensees. AOB, p. 33, ¶ 3. Quite apart
from the question being settled law in California, a court should
go beyond the literal language of a statute if reliance on that
language would defeat the plain purpose of the statute. Bob
Jones University v. United States, (1983) 461 U.S. 574, 586. If
Appellant’s logic were accepted, and the TAA only applied to
those who self-identify as talent agencies, then anyone could
circumvent the statute by simply abjuring the label, “talent
agency.”
41
Rule 8: “The purpose of defining a word within a statute is
so that that its ordinary (dictionary) meaning is not implied or
assumed.” U.S.C Rules of Statutory Construction, rule 8.
Appellant argues that the TAA violates Rule 8 because the Talent
Agencies act is silent on the proper remedy for illegal
procurement. AOB, p, 34. As noted above, when the Legislature
decided to eliminate criminal sanctions from the TAA, it left
untouched and approved the existing civil remedy of contract
avoidance and the administrative mechanism that governs how
and when it is applied. Entertainment Com. Rep., pp. 17-18.
Rule 10: “It is a violation of due process of law to employ a
‘statutory presumption,’ whereby the reader is compelled to guess

about what is included in the definition of a word, or whereby all
that is included within the meaning of a term defined is not
described SOMEWHERE within the body of law or Title in
question.” U.S.C Rules of Statutory Construction, rule 10.
Appellant once again selectively chooses a portion of the
applicable rule and argues that the TAA violates Rule 10 of
statutory construction because without clarity as to what
procurement activities may be unlawful, the statute scheme is
unconstitutional as applied. AOB p. 38-42. However, the text of
the provision makes it plain that “procuring employment” is the
activity which talent agencies must obtain a license; it is
irrelevant that licensed agencies “may in addition” do other
functions for which a license is not required. As noted above, this
challenge to the meaning of procurement was rejected in Wachs
42
v. Curry, (1993) 13 Cal.App.4th 616, 628 and in Marathon, (2008)
42 Cal.4th at 987.
Rule 12: “Expressum Facit Cessare Tacitum Rule: what is
expressed makes what is silence cease: where we find express
declaration we should not resort to implication.” U.S.C Rules of
Statutory Construction, rule 12. Appellant argues that the TAA
violates Rule 12 because they feel that the Commissioner’s
interpretation of the TAA is not just unsupportable, it is absurd
and extrajudicial. AOB, p. 42, ¶ 2. Once again, Appellant ignores
that (a) more than 100 years of common law establishes that
contracts in violation of law are unenforceable, (b) statutory
authority enacted in 1872, and (c) decades of cases enforcing

these principles.
Rule 14: “Statute that do not specifically identify ALL of
the things or classes of things or persons to whom they apply are
considered ‘void for vagueness’ because they fail to give
‘reasonable notice’ to the reader of all the behaviors that are
prohibited and compel readers to make presumptions or to guess
at their meaning.” U.S.C Rules of Statutory Construction, rule
14. Appellant argues that the TAA violates Rule 14 because no
person of ordinary intelligence would know they are in violation
of Labor Code §1700.4 (a) and 1700.5. and be able to ascertain
that one must have a talent agency license to help change the
professional plateau of their artist clients. AOB, p. 43, ¶ 1.
Considering Appellants decades of litigation about this, and the
decades of cases enforcing the TAA, this assertion is beyond
absurd. Procurement is limited to licensed agents for the
43
protection of talent, and where someone other than a licensed
talent agent engages in procurement, the conduct is illegal.
What is so confusing about that?
Rule 15: “Judges may not extend the meaning of words
used within a statute, but must resort ONLY to the meaning
clearly indicated in the statute itself.” U.S.C Rules of Statutory
Construction, rule 15. Appellant argues that the TAA violates
Rule 15 of statutory construction because there is no specified
prohibition or remedy included in the statute. AOB, p. 44, ¶ 3.
Here, avoidance of an illegal contract is a commonly recognized
remedy based upon illegality, and therefore well within the
authority delegated to judges or administrative agencies.

Rule 17: “Noscitur a sociis rule. Noscitur a sociis, dictates
that ‘words grouped in a list should be given related meaning.’”
U.S.C Rules of Statutory Construction, rule 17. Appellant argues
that the TAA violates Rule 17 of because the list of terms in
§1700 don’t properly define an occupation. However, §1700.4
plainly states: A “[t]alent agency” is defined as “a person or
corporation who engages in the occupation of procuring, offering,
promising, or attempting to procure employment or engagements
for an artist or artists . . . .”
Rule 21: “Laws are void if they are vague.” U.S.C Rules of
Statutory Construction, rule 21. Appellant argues that the TAA
violates Rule 21 because of vagueness and what they feel is
inequities of enforcement from the Labor Commissioner. AOB, p.
46, ¶ 3). There is nothing vague in the definition of procurement
or the restriction of talent agency activity to licensed agents.
44
8. The Statute and Case Law Give the
Commissioner Ample Standards to Guide Her
Exercise of Discretion
Appellant argues that Respondent’s case is the first and
only time the Commissioner has found CA Civil Code §1598 and
§1599 gives her authority to void the contractual rights of
unlicensed procurers who violate CA Labor Code §1700.4 (a) and
1700.5 and therefore makes the TAA the epitome of
unconstitutionally vague. AOB, p. 47-48. However, as this Court
is aware, these statutes enacted in 1872 simply reflected common
principles of common law recognized by the legislature at that
time. These are not new provisions; they are statutory

recognition of existing law. Regardless, there are more than
sufficient standards in the statute. California cases have
examined the term “procure” and concluded that its common
meaning suffices. “To ‘procure’ means ‘to get possession of:
obtain, acquire, to cause to happen or be done: bring about.’”
Wachs v. Curry, (1993) 13 Cal. App. 4th 616, 629 (citing Webster’s
New Internat. Dict., (3d ed. 1981), p. 1809). The Wachs decision
also observed that: “[t]he term ‘procure’ in connection with
employment is used in numerous California statutes. The fact
none of these statutes has ever been challenged is some evidence
the term is well understood.” Id. & n.3 (citing Cal. Bus. & Prof.
Code §§ 9997 (e) and (f); 9998.1(c); Cal. Civil Code §§
1812.501(a)(1)(A) and 1812.509(d); Cal. Elec. Code § 29620; and
Cal. Lab. Code § 1540; and noting that the issue has been raised,
but not reached, in just one California case).
45
Finally, administrative deference is unnecessary because
the statutory phrase, “procure employment” is unambiguous. In
sum, Appellant cannot carry its burden to show both that the
statute is so vague that a person of ordinary intelligence cannot
ascertain what is prohibited, or that it is impermissibly vague in
all of its applications, or that it is in any way unconstitutional as
applied to personal managers.
B. NEITHER THE TAA NOR ITS APPLICATION
VIOLATE THE THIRTEENTH AMENDMENT
Appellant contends that since a violation of the TAA sets
up a basis for avoiding a covered contract, it deprives personal
managers of compensation for unlicensed services and therefore

violates the Thirteenth Amendment. AOB, p. 12, ¶ 3. Appellant
provides no factual or legal argument in his brief to support this
contention.
Regardless, “[t]he Supreme Court has traditionally found
involuntary servitude to exist only where “the victim had no
available choice but to work or be subject to legal sanction.”
United States v. Kozminski, (1988) 487 U.S. 931, 943.
Whatever the “real world” constraints on Appellant or
Plaintiffs’ options, they do not rise to the level of “the use or
threatened use of physical or legal coercion” found to be the
essence of involuntary servitude in Kozminski, supra, 487 U.S. at
944. And long before Kozminski, this court had dispelled the
notion that the Thirteenth Amendment can be implicated in
contractual relationships where a party is free not to contract. In
Wicks v. Southern Pac. Co., (9th Cir. 1956) 231 F.2d 130, 138,
46
railroad workers who refused to become members of labor unions
challenged the constitutionality of union shop clauses in the
collective bargaining agreements between the unions and the
railroads. The challenged clauses permitted the unions to order
the employing railroads to dismiss the plaintiffs. The Ninth
Circuit rejected the workers’ contention that this arrangement
resulted in their involuntary servitude. Even though quitting
would cause the workers serious financial hardships, the
Thirteenth Amendment did not apply because the workers were
“not being compelled or coerced to work against their will for the
benefit of another.” Id. at 138.
Likewise here, the fact that Appellant and Plaintiffs’ can

choose not to manage artists, or can avoid procuring employment
for them, or can collaborate with a licensed talent agent or simply
get a license, takes this matter outside the Thirteenth
Amendment. Finally, this argument was rejected in National
Conference of Personal Managers Inc. v. Brown, 2015 WL
4873541, CV 12-09620 DDP (RZx) (C.D. Cal. 2015).
C. NEITHER THE TAA NOR ITS APPLICATION
VIOLATE THE EXCESSIVE FINES CLAUSE OF
THE 8TH AMENDMENT OF THE US
CONSTITUTION
Appellant argues that as applied, the TAA violates the
Excessive Fines Clause of the 8th Amendment of the United
States Constitution. AOB, p. 48. The Excessive Fines Clause of
the 8th Amendment states that “excessive bail shall not be
required, nor excessive fines imposed, nor cruel nor unusual
47
punishments inflicted.” However, Appellant’s argument relies on
his continued misinterpretation that the Act has no fine, no
penalty and no consequence and therefore the Commissioner’s
application and enforcement of contract voidance is a violation of
the Excessive Fines Clause. AOB, p. 49, ¶ 3.
But that argument is directly foreclosed by Marathon,
Waisbren, and the general rule of contract voidness in California
law. In Marathon, the California Supreme Court affirmed that
the right approach is to interpret the TAA in light of general
contract law, "giving effect to both." Marathon, 42 Cal. 4th at 991.
The touchstone is legislative intent; and for the TAA, the
Legislature specifically removed the existing criminal sanction

because it believed that the remedy of contract voidness was an
appropriate sanction. See Waisbren, 41 Cal. App. 4th at 262.
Thus, as interpreted by the California courts, the remedy for
violating the TAA is clear. And this is the interpretation of
California law that the Court must follow, not Appellants.
Appellant further attempts to undercut the California
courts’ interpretation of the TAA on the basis that there is no
notice whatsoever of either there being a law prohibiting
unlicensed procurement or any consequence for ignoring
regulation. AOB, p. 50. But this is true of all illegal contracts;
whether or not the “reasonable person” can find a precise Civil
Code citation, they know that the contract is illegal because the
Legislature has elsewhere declared certain conduct illegal. Cf
Kashani v. Tsann Kuen China Enter. Co., (2004) 118 Cal. App.
4th 531, 540-43 (survey of contract illegality). The "reasonable
48
person['s]" purported lack of knowledge of the Civil Code does not
transform their illegal contract into a legal one.
Along the same lines, Appellant has attempted to argue
that the TAA is vague because it is structured differently than
other licensing statutes. AOB, p. 28-31. This line of argument is
irrelevant; as demonstrated above, licensing schemes differ, and
however other licensing schemes are structured, the Legislature
clearly intended that contracts made in violation of the TAA be
void.
This line of argument is also overstated. Some licensing
schemes include an explicit prohibition on recovery for unlicensed
work. ·See, e.g., Cal. Bus. & Prof. Code § 7031 (contractors); Cal.

Ins. Code § 15006(b) (insurance adjustors). But others -- like the
TAA -- do not. They are either silent and are governed by the
Civil Code described above, or they are silent and are governed
by a distant provision in the Business and Professions Code
(section 143). See, e.g., Cal. Bus. & Prof. Code §§ 6125, 6126
(attorneys); Cal. Lab. Code§§ 1706 et seq. (child performer
services permits); Cal. Food & Agric. Code§§ 14591 et seq.
(distributors of fertilizing materials).
For example, if an unlicensed attorney were to look at the
text of Business and Professions Code sections 6125 and 6126,
which prohibit the unauthorized practice of law, they would not
see statutory text informing them that they might not be
compensated for their unlawful work. Yet there is no question
that contracts to unlawfully practice law are void. See Golba v.
Dick's Sporting Goods, Inc., (2015) 23 8 Cal. App. 4th 1251, 1261;
49
see also McIntosh v. Mills, (2004) 121 Cal. App. 4th 333 (illegal
fee-sharing agreement).
In this respect, the TAA is no more vague than other
licensing statutes. Although other licensing schemes include both
a criminal penalty and contract voidness, the TAA, the
Legislature determined that the lesser penalty of contract
voidness was sufficient. Entertainment Com. Rep., pp. 17-18.
Presumably Appellant, a personal manager and repeat offender,
would not want the Legislature to add back a criminal sanction
for violations of the TAA.
VII. CONCLUSION
For all the foregoing reasons, Respondent respectfully

requests that the Court affirm the judgment, dismiss the appeal,
and award Respondent costs as permitted by the Cal. Rules of
Court.
/s/ Jude Salazar

Jude Salazar
Respondent in pro per
50
CERTIFICATE OF WORD COUNT
(California Rules of Court, Rule 8.204(c)(1))
The undersigned Respondent in pro per hereby certifies
that pursuant to Rule 8.204 of the California Rules of Court, the
foregoing Respondents’ Brief is produced using 13-point Century
type and contains less than 12,000 words, including footnotes,
which is fewer than the 14,000 words permitted by rule for this
brief.
The undersigned Respondent in pro per relies on the word
count of the computer program (MS Word) used to prepare this
brief.

/s/ Jude Salazar
Jude Salazar
Respondent in pro per
51
PROOF OF SERVICE
I am over the age of 18 and a party to the within action.
On August 23, 2024, I served the within document(s) described
as:
RESPONDENT’S BRIEF
on the interested parties in this action as stated on the attached

mailing list.
X (BY MAIL) By placing a true copy of the foregoing document(s) in

a sealed envelope addressed as set forth on the attached mailing list.
I am readily familiar with this firm's practice for collection and
processing of correspondence for mailing. Under that practice, it
would be deposited with the U.S. Postal Service on that same day
with postage thereon fully prepaid in the ordinary course of business.
I am aware that on motion of the party served, service is presumed
invalid if postal cancellation date or postage meter date is more than
one day after date of deposit for mailing contained in affidavit.

(BY PERSONAL SERVICE) I delivered a true copy of the
foregoing document(s) in a sealed envelope by hand to the offices of
addressee(s) on the attached mailing list.
X (BY E-MAIL) By transmitting a true copy of the foregoing

document(s) to the e-mail addresses set forth on the attached mailing
list.
I declare under penalty of perjury under the laws of the State of
California that the foregoing is true and correct.
Executed on August 23, 2024, at Los Angeles, California.
Jude Salazar /s/ Jude Salazar

(Mail and Email) (Signature)
52
SERVICE LIST
Judge Barbara Meiers via U.S. Mail

Los Angeles County
Superior Court
Stanley Mosk Courthouse
111 N. Hill Street
Department 12
Los Angeles, CA 90012
Diane Pardoe/Sarah Pardoe via Email

312 N. Kenwood St. Apt. A
Burbank, CA 91505
323.363.3803 Phone
[email protected]
[email protected]
Rick Siegel, via Email

22971 Darien St.
Woodland Hills 91364

[email protected]
Casey Raymond via Email

Division of Labor
Standards Enforcement
[email protected]
53

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Case No.

THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

Diane Pardoe et. al,

Document received by the CA 2nd District Court of Appeal.

Appeal from An Order of the Los Angeles County Superior Court

Respondent In Pro Per

Pursuant to California Rules of Court, rule 8.208(e), the

Dated: August 23, 2024 Respectfully submitted,

Document received by the CA 2nd District Court of Appeal.

CERTIFICATE OF INTERESTED PARTIES ................................ 2

TABLE OF CONTENTS .................................................................. 3

TABLE OF AUTHORITIES ............................................................ 5

II. STANDARD OF REVIEW ...................................................... 13

III. STATEMENT OF THE CASE – PROCEDURE .................... 14

IV. THE PARTIES’ POSITIONS.................................................. 16

A. Summary of the Case ................................................. 16

Document received by the CA 2nd District Court of Appeal.

A. Purpose of the TAA .................................................... 21

VI. ARGUMENT .......................................................................... 26

A. THE TAA IS NOT UNCONSTITUTIONALLY

Document received by the CA 2nd District Court of Appeal.

VII. CONCLUSION ..................................................................... 50

Bacall v. Shumway (2021)

BMW of America v. Gore (1995)

Bob Jones University v. United States (1983)

Buchwald v. Katz (1972)

Buchwald v. Superior Court (1967)

Daily v. Bond (9th Cir. 1980)

Document received by the CA 2nd District Court of Appeal.

Dyna-Med, Inc. v. Fair Employment & Housing Comm. (1987)

Foti v. City of Menlo Park (9th Cir.1998)

Golba v. Dick's Sporting Goods, Inc. (2015)

Grayned v. City of Rockford (1972)

Holder v. Humanitarian Law Project (2010)

Hoye v. City of Oakland (9th Cir. 2011)

Human Life of Washington Inc. v. Brumsickle (9th Cir. 2010)

Johnson v. Frankell (1997)

Lambert v. California (1957)

Legal Aid Services of Oregon v. Legal Services Corp (9th Cir.2010)

Loving & Evans v. Blick (1949)

Marathon Inc. v. Blasi (2008)

McIntosh v. Mills (2004)

Nat’l Abortion Fed’n v. Gonzales (2d Cir. 2006)

Document received by the CA 2nd District Court of Appeal.

National Endowment for the Arts v. Finley (1998)

Park v. Deftones (1999)

People v. Cromer (2001)

Pineda v. Williams-Sonoma Stores, Inc. (2011)

Styers v. Ryan (9th Cir. 2015)

United States v. Kozminski (1988)

United States v. Petrillo (1947)

Village of Hoffman Estates v. Flipside, Hoffman

Wachs v. Curry (1993)

Waisbren v. Peppercorn Productions, Inc. (1995)

Document received by the CA 2nd District Court of Appeal.

Washington State Grange v. Washington State

Wicks v. Southern Pac. Co. (9th Cir. 1956)

Wood v. Krepps (1914)

Yoo v. Robi (2005)