Appellant Reply Brief: NCOPM V Gov. Brown, Attorney General Harris, Labor Commissioner

Case No.
13-55545
UNITED STATES COURT OF APPEALS
FOR THE NINTH CIRCUIT
__________________________________________________________
National Conference of Personal Managers, Inc.
Plaintiff-Appellant
vs.
Edmund G. Brown, Jr. et al
DefendantsAppellees
__________________________________________________________
Appeal from United States District Court, Southern District of California
District Court Case Number CV 12-09620
The Honorable Dean D. Pregerson, Judge, Presiding
__________________________________________________________
APPELLANTS REPLY BRIEF
__________________________________________________________
STEPHEN F. ROHDE (SBN 51446) CHRISTOPHER B. GOOD (SBN 232722)
LAW OFFICES OF STEPHEN F. ROHDE RYAN H. FOWLER (SBN 227729)
1801 Century Park East, Suite 2400 FRANK W. FERGUSON, II (SBN 211694)
Los Angeles, CA 90067 FOWLER & GOOD LLP
Tel: (310) 277-1482 15303 Ventura Boulevard, 9
th
Floor
Fax: (310) 772-0405 Sherman Oaks, CA 91403
Tel: (818) 302-3480
Fax: (818) 279-2436

Attorneys for Appellant National Conference of Personal Managers, Inc.
Case: 13-55545 01/16/2014 ID: 8941711 DktEntry: 36 Page: 1 of 42

i
TABLE OF CONTENTS
I. INTRODUCTION .................................................................................................. 1

II. ARGUMENT ........................................................................................................ 4

A. APPELLEES FAIL TO ADDRESS FLAWS IN THE TAA ............................ 4

B. APPELLEES FAILED TO ADDRESS APPELLANTS CLAIMS THE TAA
IS UNCONSTITUTIONALLY VAGUE IN VIOLATION OF THE DUE
PROCESS CLAUSE ............................................................................................11

C. APPELLEES FAILED TO PROPERLY ADDRESS CLAIMS THE TAA
BURDENS AND RESTRICTS COMMERCIAL SPEECH IN VIOLATION OF
THE FIRST AMENDMENT ................................................................................17

D. APPELLEES DO NOT ADDRESS CLAIMS THAT THE TAA VIOLATES
THE COMMERCE CLAUSE ..............................................................................21

E. APPELLEES FAILED TO ADDRESS CLAIMS THAT WITHOUT A
PENALTY PROVISION THE LABOR COMMISSIONER HAS NO
AUTHORITY TO USE THE TAA TO IMPAIR CONTRACTS .........................23

F. APPELLEES FAILED TO ADDRESS CLAIMS THAT THE TAA IMPAIRS
THE OBLIGATIONS OF CONTRACTS IN VIOLATION OF ARTICLE I,
SECTION 10 OF THE U.S. CONSTITUTION ....................................................26

G. APPELLEES IGNORED APPELLANTS CLAIMS THAT IN VOIDING
THE RIGHT TO COMPENSATION FOR LABOR WITHOUT CLAIMS OF
FRAUD OR NON-PERFORMANCE, TAA ENFORCEMENT VIOLATES THE
THIRTEENTH AMENDMENT ..........................................................................29

I. APPELLEES FAIL TO ADDRESS OTHER CLAIMS ..................................33

III. CONCLUSION ..................................................................................................34

CERTIFICATE OF COMPLIANCE .......................................................................36

CERTIFICATE OF SERVICE ................................................................................37

ii
TABLE OF AUTHORITIES

FEDERAL CASES

Bailey v. Alabama, 219 US 219, 241 (1911) ...........................................................32
BMW of America v. Gore, 517 U.S. 559, 574 (1995) ..............................................24
Chevron, U.S.A., Inc. v. Natural Resources Defense Council 467 U.S. 837 (1984)
..............................................................................................................................13
Crane v. Hahlo, 258 U.S. 142 (1922), .....................................................................27
Edenfield v. Fane, 507 U.S. 761 (1993) ..................................................................20
Flagg Brothers v. Brooks, 435 U.S. 149 (1978) ......................................................19
Giboney v. Empire Storage & Ice Co., 336 U.S. 490 (1949) ..................................18
Hoffman Est. v. The Flipside, Hoffman Est., Inc., 455 U. S. 489 (1982) ................18
New York Times v. Sullivan, 376 U.S. 254 (1964) ..................................................19
Ohralik v. Ohio State Bar Association, 436 U.S. 447 (1978) ..................................19
Rendall-Baker v. Kohn, 457 U.S. 830 (1982) ..........................................................19
Smith v. Bach, 183 Cal. 259 (1920) .......................................................... 8, 9, 10, 28
Sorrell v. IMS Health, Inc., 564 U.S. 15 (2011) ......................................................18
Tidal Oil Co. v. Flanagan, 263 U.S. 444, 451 (1923) .............................................27
United States v. Evans, 333 U.S. 483 (1948) ...........................................................25
United States v. Kozminski, 487 U.S. 931 (1988) ....................................................30
Virginia State Board Of Pharmacy v. Virginia Citizens Consumer Council, 425
U.S. 478 (1976) ....................................................................................................18

STATE CASES

Albaugh v. Moss Constr. Co., 125 Cal. App. 2d 126 (1954) ........................ 9, 10, 11
Buchwald v. Superior Court, 254 Cal. App. 2d 347 (1967) ............. 5, 6, 8, 9, 10, 11
Loving & Evans v. Blick, 33 Cal. 2d 603 (1949) ...................................... 8, 9, 10, 28

iii
Severance v. Knight-Counihan Co., 29 Cal. 2d 561 (1947) ......................... 8, 10, 28
Wood v. Krepps, 168 Cal. 382 (1914) ................................................. 8, 9, 10, 28, 29
STATUTES

42 USC 1983 ........................................................................................................... 1
CA Business & Professions Code 6068 ................................................................24
CA Business & Professions Code 7028 ................................................................10
CA Business & Professions Code 9887.2 ............................................................... 7
CA Labor Code 1700 et seq. (Talent Agencies Act) .............................................. 1
CA Labor Code 1700.4(a) .............................................................................. 15, 17
California Civil Code 1599 ...................................................................................26
OTHER AUTHORITIES

Brief for Music Managers Forum-US et al. as Amicus Curiae ................................. 8
Brief for SAG-AFTRA et al. as Amicus Curiae ......................................................11
Historical and Statutory Notes of Labor Code 1701 ............................................16
Report of the CA Entertainment Commission .........................................................16
Strang, Lee J., Federal Constitutional Law: Federalism Limitations on State and
Federal Power, Vol. 4 (2011) ...............................................................................28

CONSTITUTIONAL PROVISIONS

Art. 1, Sec. 8 (Commerce Clause) ............................................................ 1, 2, 21, 23
Art. 1, Sec. 10 (Contracts Clause)............................................................. 1, 2, 26, 28
First Amendment ..................................................................................................2, 17
Fourteenth Amendment ............................................................................................. 1
Tenth Amendment ................................................................................................2, 22
Thirteenth Amendment ........................................................................................3, 29

iv
LABOR COMMISSION DETERMINATIONS

Behr v. Dauer and Assoc. (TAC 21-00) .................................................................... 5
Blasi v. Marathon (TAC 15-03) ..............................................................................4,5
Creative Artists Group v. Jennifer ODell (TAC 26-99) ........................................... 5
Gittlemann v. Karolat (TAC 24-02) .......................................................................4,5
Jewel v. Inga Vainshtein (TAC 02-99) ...................................................................... 5
Macy Gray v. Lori Leve Management (TAC18-00) ...............................................4,5
Park v. Deftones (TAC 9-97) ..................................................................................4,5
Parker Posey v. Lita Richardson (TAC 7-02) ........................................................... 5
Solis v Blancarte, TAC 27089 (October 2013)................................................. 5, 6, 8
Tool v. Larrikin Management (TAC 35-01) .............................................................. 5
Transeau v. 3 Artist Mgmt. (TAC 73-06) .................................................................. 5
Wesley Snipes v. Delores Robinson (TAC 36-96) ..................................................... 5


1
I. INTRODUCTION
Appellants Opening Brief ("AOB") details how the California Talent
Agencies Act ("TAA") is facially and as applied unconstitutional, in violation
of the Contracts Clause, Commerce Clause, First, Thirteenth and Fourteenth
Amendments of the U. S. Constitution. As a result, Appellees under color of the
TAA have subjected Appellant and its members to the deprivation of their
rights, privileges and immunities secured by the U. S. Constitution in violation
of 42 USC 1983.
Appellees Answering Brief ("AAB") attempts to support the District
Court's ruling dismissing the Complaint with prejudice. As detailed below,
Appellees arguments fail as a matter of law, are unsupported by case law or
rely upon misleading, incomplete, false or nonexistent citations. Appellees
often simply fail to dispute or challenge Appellants arguments, conceding their
merit.
Attempting to persuade the Court that the TAAs Fourteenth Amendment
constitutionality is well settled, Appellees fail to recognize that the one
precedent on which all TAA determinations are founded is legally
unsupportable. Appellees ignore how the TAA fails to provide clear notice of
who is regulated, what if anything is regulated and what are the consequences
for ignoring a regulation. Appellees also fail to address Appellants claim that

2
without a penalty provision enacted by the Legislature, the Labor
Commissioner has no authority to invoke the TAA to impair contracts or order
disgorgement.
As a direct result of the lack of adequate notice in violation of their rights
to due process, Appellants First Amendment right to free speech is greatly
hindered and restrained. Regardless of his intent or motivation at the time a
statement is made, a personal manager cannot be certain whether what he says
may someday be used against him in support of a claim that his words violated
the TAA. Commercial speech proposing a transaction is afforded protection
under the First Amendment.
Appellees mislead the Court by refusing to acknowledge or ignoring the
fact that no TAA licensee is wholly domiciled outside the State of California.
Under the Tenth Amendment, states are powerless to license business
occupations or premises outside their sovereign borders. The TAA imposes a
license tax on interstate commerce and is an economic protectionist act favoring
in-state licensees over out-of-state competitors all violations of the
Commerce Clause.
Appellees argument that the TAA does not violate the Contracts Clause
fails as a matter of law and legislative intent. Appellees fail to establish that the
Legislature ever considered voiding contractual rights for TAA violations and

3
concede that forfeitures denying compensation for services already rendered are
not favored in law.
Appellees also fail to dispute that the Commissioner's enforcement of the
TAA unconstitutionally voids contractual rights to compensation without
findings or fraud, non-performance or criminality, in violation of the Thirteenth
Amendment.
Appellees do not credibly dispute Appellants contention that the District
Court abused its discretion by failing to consider the Complaint in its entirety.
Appellees have quoted citations inappropriately, out of context or falsely.
Appellees overriding theme is, If we say it is so and we say it is so over and
over, it must be so. Appellees attempt to defend an indefensible statute and its
unconstitutional, unlawful enforcement; resulting in the forfeiture of an
estimated $500,000,000 in otherwise-owed compensation.
1

It is manifest that the Complaint alleges plausible, indeed highly persuasive,
constitutional claims, which were prematurely dismissed with prejudice. The
District Court's ruling should be reversed and the TAA should be declared
unconstitutional, or at a minimum, the case should be remanded to the District
Court.

1
Johnson, Ted, Showbiz Managers Seek Appeals Court Ruling on Talent Agencies
Act, Variety (Oct. 9, 2013).

4
II. ARGUMENT
A. APPELLEES FAIL TO ADDRESS FLAWS IN THE TAA
The Court needs look no further than Macy Gray (TAC 18-00) and
Deftones (TAC 9-97), plus Gittleman (TAC 24-02) and Blasi (TAC 15-03) to
be provided with a front row seat to the unconstitutional inequities and
violations perpetrated on Appellants via the TAA. In Macy Gray and Deftones,
each artists manager arranged and coordinated a showcase for their clients
before music industry executives. After only one showcase, Gray procured a
recording contract. The Deftones manager tenaciously repeated approximately
83 times the exact same actions as Grays manager before his artist procured a
recording contract. Both artists sought to terminate their management contracts
and avoid paying their managers by claiming that their managers procured
employment in violation of the TAA. The same identical act of alleged
procurement occurred in each case, but the Commissioners rulings were
completely different. Grays manager was found not to have violated the TAA,
while the Deftones diligent manager was found to have violated the TAA.
These discrepancies are not limited to music. In the following cases, the
artist appeared on a TV talk show. Both artists later sought to have their
contracts terminated by claiming their managers had violated the TAA by
procurement. Gittleman (TAC 24-02) holds that a talent agency license is

5
not required for the procurement of a guest appearance on a talk show
provided the appearance does not involve the rendition of artistic
services. Id., p. 27. But in Blasi (TAC 15-03), decided the same year
as Gittleman, the Commissioner ruled that helping an actress procure
appearances on three talk shows (where the actor was not acting) did
violate the TAA. Id., p. 21. Same facts, same year, opposite rulings. How is
the TAA anything other than unconstitutional?
The Commissioners contrary decisions with identical fact patterns are the
epitome of arbitrary and unconstitutional enforcement. See Determinations
2

Appellees ignored. AOB, pp.20-23.
Equally important, Buchwald v. Superior Court, 254 Cal. App. 2d 347
(1967), nearly twenty years prior to the 1985 enactment of the TAA, relied on
by Appellees (AAB, p.9) and the one precedent on which all TAA
determinations are founded when assigning remedies, is legally unsupportable.
Most recently, in Solis v Blancarte, TAC 27089 (October 2013) the Labor
Commissioner ruled:

2
Wesley Snipes v. Delores Robinson (TAC 36-96), Creative Artists Group v.
Jennifer ODell (TAC 26-99), Behr v. Dauer and Assoc. (TAC 21-00), Tool v.
Larrikin Management (TAC 35-01), Transeau v. 3 Artist Mgmt. (TAC 73-06),
Parker Posey v. Lita Richardson (TAC 7-02), Jewel v. Inga Vainshtein (TAC 02-
99), Gittlemann v. Karolat (TAC 24-02), Blasi v. Marathon (TAC 15-03), Macy
Gray v. Lori Leve Management (TAC18-00), Park v. Deftones (TAC 9-97).

6
Since the clear object of the Act is to prevent improper
persons from becoming [talent agents] and to regulate such
activity for the protection of the public, a contract between an
unlicensed [talent agent] and the artist is void." Solis Supra,
p.9, lines 3-11; quoting Buchwald, p.351.

Appellees have offered no evidence Californias legislature ever sought to
prevent "improper persons" becoming talent agents or intended to void the
contracts of unlicensed persons who procure employment for an artist.
If California wanted to ensure "improper persons" did not become talent
agents, it would have codified conditions of competence, experience and/or
education as a barrier to obtaining a license, as it does for lawyers, contractors,
doctors, etc.
James Blancarte, Esq. is a transactional entertainment attorney, the first
lawyer whose contractual right to compensation were voided by the
Commissioner under the TAA. The Commissioner determined that Blancarte
had renegotiated sportscaster Mario Solis's employment contract without a
TAA license or working with a licensed agent. Solis supra, p.8, ln.1 p.9, ln.2.
To practice law, attorneys must meet the academic qualifications to
graduate from law school, pass the bar exam and every three years thereafter
meet continuing education requirements.
Conversely, applicants for a TAA license need only complete a few forms,
(see http://www.dir.ca.gov/dlse/talent_agency_license.html) obtain two

7
personal recommendations, submit fingerprints, remit a $50,000 bond and pay a
$250 fee (which violates the Commerce Clause). AOB pp.36-37. Even
applicants for an automobile lamp and brake adjustors license must
demonstrate basic experience and qualifications (CA Business and Professions
Code 9887.2.)
The TAA has no such requirements.
Transactional attorneys specialize in drafting and negotiating contracts, skills
that benefits artists. But as interpreted by the Commissioner, artists who want the
benefit of legal advice must also add the financial burden of engaging a separate
talent agent. As attorneys generally charge 5% and agents 10%, how does hiring a
non-specialist at twice the cost protect the artist, or three times the cost if both an
agent and attorney are used? Solis was not looking for a new job; he wanted help
renegotiating with his current employer.
Appellees argue the enforcement of the TAA should be affirmed despite
presenting no evidence that the Legislature wanted to reserve procurement to
proper individuals. Limiting procurement to licensees may be the Labor
Commissioners purpose, but it clearly has never been the Legislatures, nor
does it serve artists or anyone else.
Appellees present a list of supposed protections offered under the TAA in
support of maintaining that the TAA serves an important public policy. Of all

8
the claimed protections, not a single one is unique to the TAA and in fact all
protections listed by Appellees already exist in the law of contracts and
consumer protection. The TAA does not promote a necessary public policy. To
the contrary, it creates unnecessary confusion and uncertainty at the expense of
Appellants constitutional rights. This point reaffirms the foundational claim of
the Southwest Law Schools amicus brief: Appellees enforcement of the TAA
fails the rational basis test.
Appellees argument that the Commissioner only acts in a quasi-judicial,
not quasi-legislative capacity also fails. AAB, p.25. By inventing prohibitions
and consequences to unlicensed procurement, the Commissioner acts as an
unelected super-legislator.
But beyond the fact that Appellees have invented a clear purpose for the
TAA that is directly contrary to the actual, documented and unrefuted purpose
of protecting artists from employers masquerading as agents (AOB, p.42), the
purported authority for voiding contracts is downright bewildering. The recent
Blancarte Determination and previous TAA Determinations founded upon
Buchwald ignore the five citations on which Buchwald is supposedly based:
Wood v. Krepps, 168 Cal. 382 (1914), Loving & Evans v. Blick, 33 Cal. 2d 603
(1949), Smith v. Bach, 183 Cal. 259 (1920), Severance v. Knight-Counihan Co.,
29 Cal. 2d 561 (1947) and Albaugh v. Moss Constr. Co., 125 Cal. App. 2d 126

9
(1954). In fact, Buchwald conflicts with all five cases which actually hold that
voiding a contract is only proper under circumstances that do not exist in the
TAA.
Wood refused to void a contract because the relevant licensing scheme did
not, declare that a contract made by any one in the conduct of the various
businesses for which licenses are provided to be procured under the ordinances,
shall, if a license is not obtained, be invalid; nor is there any provision therein
indicating in the slightest that this failure was intended to affect in any degree
the right of contract. Id., p.386. As the TAA neither declares contracts of
unlicensed people invalid nor in any way indicates such failures should affect
the right of contract, instead of supporting Wood, Buchwald contradicts Wood.
Loving & Evans held, "it has been repeatedly declared in this state that a
contract made contrary to the terms of a law designed for the protection of the
public and prescribing a penalty for the violation thereof is illegal and void, and
no action may be brought to enforce such contract." Id., pp.608-609 (emphasis
added). As the TAA has no prescribed penalty whereby procuring employment
for artists without a license is "illegal and void," Buchwald contradicts Loving.
Smith held, "the imposition by statute of a penalty implies a prohibition of
the act to which the penalty is attached, and a contract founded upon such act is

10
void." Id., p.262 (emphasis added). Since the TAA has no penalty provision,
Buchwald contradicts Smith.
Severance held, [i]f the statute does not provide expressly that its
violation will deprive the parties of their right to sue on the contract, and the
denial of the relief is wholly out of proportion to the requirements of public
policy or appropriate individual punishment, the right to recover will not be
denied. (Citation omitted.) Id., p.568. Instead of supporting Severance,
Buchwald contradicts Severance.
Albaugh is a California Contractors Act dispute. CA Business &
Professions Code 7028 expressly prohibits non-licensees from engaging in
the activities of a contractor and 7031 expressly prohibits compensation for
unlicensed work. See Id,, pp.131-132. As the TAA has neither a prohibitive
provision like 7028 nor a penalty provision like 7031, Buchwald contradicts
Albaugh.
We agree with Appellees that [w]hen interpreting state law, federal
courts are bound to follow the decisions of the states highest court. AAB,
p.20. Under Wood, Loving, Smith and Severance, administrative agencies only
have authority to impair contracts or void a contract when a statute provides
notice of the prohibition and prescribes a penalty. Buchwald does not claim to
be a change in law or interpretation; it claims to follow Wood, Loving, Smith,

11
Severance and Albaugh. This Court should follow the cases Buchwald
inexplicably contradicts.
Appellees blindly rely on Buchwald four times. AAB, pp.9,13,25,29.
Appellees even argue that TAA enforcement is constitutional because it has
been validly applied for more than 25 years,
3
an argument obliterated by
recognizing that Buchwald and therefore all subsequent TAA precedents are
founded upon misinterpretations of the law consistently recognized in Wood,
Loving, Smith, Severance and Albaugh.
4

B. APPELLEES FAILED TO ADDRESS APPELLANTS CLAIMS
THE TAA IS UNCONSTITUTIONALLY VAGUE IN VIOLATION
OF THE DUE PROCESS CLAUSE
Due process requires that the procedures by which laws are applied must
be evenhanded, so that individuals are not subjected to the arbitrary exercise of
government power. This requires that the individual be given adequate notice.
Notice should provide sufficient detail to fully inform the individual of the
decision or activity that will have an effect on his/her rights or property or
person. There must be clear notice of prohibitions and the consequences of

3
Contrary to Unions amicus claim, Courts have repeatedly upheld the [TAAs]
constitutionality, no appellate court has ever ruled on its application. AOB, p.19.
4
Appellees also fail to address how the applicability of Buchwald is eviscerated
with the recognition that in 1967, when it was decided, the scheme had a penalty
provision that was repealed in 1982. AOB, p.6.

12
ignoring them. The TAA fails to provide adequate notice of who is subject to
regulation, what conduct is covered by regulation and what the penalty is for
violation of said regulation.
Under the canon of Expression unius est exclusio arterius, courts are
obliged to assume that the only regulations the Legislature chose to enact are
those included in a list of requirements and/or prohibitions in the statute. AOB,
pp.18-19.
Appellees, in opposition to this basic tenet of law and without adequate
support or justification, argue the law of statutory construction should be
ignored in schemes like the TAA where the Legislature, delegates interpretive
and implementing power to administrative agencies. AAB, p.28. However, as
detailed by Appellants, the Labor Commission has continually provided
diametrically inconsistent rulings on matters with identical fact patterns. These
are unacceptable and unconstitutional interpretations of 1700.4 by the
Commissioner. Appellees concede that deference to an administrative agency to
interpret and implement a statute is revoked when the interpretation is plainly
erroneous or inconsistent with the regulation. AAB, p.32. Despite this
concession, Appellees refuse to acknowledge that this is precisely what is
occurring with the interpretation and implementation of the TAA.

13
Inexplicably, Appellees argue that under Chevron, U.S.A., Inc. v. Natural
Resources Defense Council 467 U.S. 837 (1984), the Labor Commission has
carte blanche to interpret the law it has been entrusted to administer, assuming
the agency was given the adjudicatory powers because, the subject matter
requires more than ordinary knowledge and the statutory construction
involves reconciling conflicting policies, and a full understanding of the force
of the statutory policy in the given situation has depended upon more than
ordinary knowledge. AAB, p.27.
Appellees misrepresent Chevron by not quoting it in full context. Rather
than leave statutory interpretation to an executive bodys singular whim, in full
context Chevron holds an administrative agencys construction should be
disturb[ed] when: (1) that construction appears from the statute or its
legislative history is not one that Congress would have sanctioned or, (2) it is
an [un]reasonable accommodation of conflicting policies (Id. p.845, citing
United States v. Shimer, 367 U.S. 374, 382, 383 (1961), Capital Cities Cable,
Inc. v Crisp, ante at 699-700) within a gap left open by [the Legislature].
Chevron supra, p.866.
The gaps in the TAA ambiguity as to who is being regulated, what, if
anything, is being regulated, and what the consequence is for ignoring the
regulations (see AOB, p.16) are obviously unreasonable. Moreover, the

14
conflicts of interpretation are of the Commissioners own making. It was the
Commissioner who ruled procuring talk show appearances violated the TAA
and months later, did not. AOB, p.22. It was the Commissioner who ruled
personal managers must be able to act proactively and not play a game of
Mother May I; but at other times ruled they can never act proactively. AOB,
p.21. If the Commissioner cannot discern the bright line between lawful and
unlawful behavior, the enforcement is unconstitutional.
In regards to who is subject to regulation under the TAA, Appellees argue
that the California Supreme Court has already considered and rejected the
claim the TAA applies only to the occupation of talent agent and provides
clarity as to whom the TAA regulates. AAB, p.20. This is incorrect. Appellees
do not and cannot refute Appellants claim that the term manager in 1700
refers to ones position in the company, not their occupation.
Appellees fail to refute Appellants argument that the TAA must be
interpreted similar to the licensing schemes that limit the use of occupational
titles to licensees, rather than limiting activities to licensees. AOB, p.17.
Just as gardeners and landscape designers can beautify outdoor areas,
bookkeepers can keep accounting records, and salespeople, teacher and lawyers
can use psychological techniques to change behavior all without having the
requisite licenses simply by abjuring the labels of landscape architects,

15
accountants and psychologists. So too can Appellants members procure
employment, as long as they do not label themselves talent agents. Appellees
do not and cannot explain why TAA enforcement should be different.
Instead Appellees incorrectly argue, If appellants logic were accepted
and the TAA only applied to those who self-identify as talent agencies, then
anyone can circumvent the statute by simply abjuring the label talent agency.
AAB, p.21.
In regards to regulated conduct, Appellees argue, the text of [Labor Code
1700.4(a)] makes it plain that procuring employment is the activity for
which talent agencies must obtain a license. AAB, p.5.
Appellees incorrectly argue only one of the three defining activities of a
talent agent creates prohibitions; the other two are irrelevant. AAB, p.18.
However, the surplusage rule cannot be discarded even if it interferes with the
Commissioners desired enforcement policies. If only one defining activity
creates a prohibition, there must be written exceptions to explain why the others
do not. AOB, p.17.
In their Summary of the Case, Appellees pretend to paraphrase the
Complaint: According to appellant, if a person has procured employment for
an artist without a license, the Labor Commissioner is empowered to impair the
contract. ER p.182, 38. AAB, p.3. This is false, misleading and inaccurate as

16
Appellants state just the opposite. The California Legislature never adopted
any statute that instructs, guides or provides the Labor Commission, which is
empowered to hear all relevant controversies, to impair the contract when i[t]
finds an individual or business has violated the [TAA]. ER, p.182.
Appellees also misappropriate legislative history. Under the guise of
providing legal background and historical legislative support, Appellees
adamantly argue that, the California Legislature reaffirmed the need for the
TAA and the TAA is necessary for the public welfare, citing the Historical
and Statutory Notes of Labor Code 1701. AAB, p.8.
Appellees are aware and know that 1700 and 1701 are not the same
statute. 1701 is a provision of CA Labor Code Chapter 4.5 regarding Fee
Related Talent Services, not the TAA. Yet despite this difference, Appellees
have employed 1701, a completely different and irrelevant code section, to
support their position regarding legislative intent. Appellees argument by any
measure is wrong in light of their faulty and improper reliance on 1701.
Appellees are aware that the legislative intent for the TAA is provided for
in the report of the CA Entertainment Commission (CEC). In fact they cite it in
their brief. AAB, p.19. But they pointedly omit the Reports specific finding
relevant to the Legislatures intent:
The principal, and philosophically the most difficult, issue
before the Commission, the discussion of which consumed a

17
substantial portion of the time of most of the meetings of the
Commission, was this first issue: When, if ever, may a personal
manager or, for that matter, anyone other than a licensed talent
agent, procure employment for an artist?
No clear legislative intent can be discerned to assist in
answering this critical and fundamental question. Id. at 7.
5

As the CEC clearly found no evidence of legislative intent after studying
this issue for three years,
6
Appellees assertion that the Legislatures intent is
made plain by reading 1700.4(a) is wholly disingenuous and completely
inaccurate. AAB, p.5.
For all of the aforementioned reasons as well as the accurate detailing of
the legislative intent it is clear that the TAA is unconstitutionally vague and
violates Appellants right to due process.
C. APPELLEES FAILED TO PROPERLY ADDRESS CLAIMS THE
TAA BURDENS AND RESTRICTS COMMERCIAL SPEECH IN
VIOLATION OF THE FIRST AMENDMENT
Appellant has presented a substantial case that the restrictions imposed by
the TAA on commercial speech cannot be justified under the current test for
restraints on commercial speech. AOB, pp.38-43.

5
The parties filed slightly different versions of the CEC Report. Both include
identical information but vary in where the TAAs Background is placed. This
citation appears on p.7 of the version submitted by Appellees and p.15 in
Appellants submission.
6
The CEC was created in 1982; (Id., p.2) the report submitted on December 2,
1985. Id., p.34.

18
Appellees argue this claim fails because Appellant failed to challenge the
TAA as overbroad. AAB, p. 38. This is not the case. "It is irrelevant whether
the ordinance has an overbroad scope encompassing other persons' commercial
speech, since the overbreadth doctrine does not apply to commercial
speech." Hoffman Est. v. The Flipside, Hoffman Est., Inc., 455 U. S. 489 (1982).
Appellees argue that based on Giboney v. Empire Storage & Ice Co., 336
U.S. 490 (1949), the commercial speech claim fails because the TAA regulates
conduct, not speech. AAB, pp.39-40. Again, this is not the case. As Giboney
considered codified provisions that prohibited the disputed conduct and the
TAA has no such provisions, Giboney is not applicable. Further, Appellees
conspicuously ignore that Giboney predates the Supreme Courts reformulation
of the commercial speech doctrine in Virginia State Board Of Pharmacy v.
Virginia Citizens Consumer Council, 425 U.S. 478 (1976). AOB, pp. 40-41.
Sorrell v. IMS Health, Inc., 564 U.S. 15 (2011) affirms that conduct of creating
and disseminating information to propose a commercial transaction is
expression protected by the First Amendment. Since 1976, speech that does no
more than propose a commercial transaction is nonetheless of such social value
as to be entitled to protection. Id., AOB, p.40; see Sorrell v. IMS Health, Inc.,
564 U.S. 15 (2011).

19
Next, Appellees incorrectly cite Ohralik v. Ohio State Bar Association, 436
U.S. 447 (1978). AAB, p.39. Rather than commercial speech, Ohralik dealt with
a lawyer engaged in the general misconduct proscribed by the Disciplinary
Rules regarding a lawyers solicitation of business through direct, in person
communication with the prospective clients. Id., p.454.
Appellees then argue this claim fails because enforcing the TAA is not a
state action. They rely on Flagg Brothers v. Brooks, 435 U.S. 149 (1978),
which dealt with private enforcement of a statutory lien and involves neither a
state agency nor state action; and Rendall-Baker v. Kohn, 457 U.S. 830 (1982).
AAB, pp.40-42. Rendall-Baker considers a private school teacher fired by a
private school. It, too, involves no state action. Here, Appellant is challenging
the interpretation and enforcement of a state statute by a state administrative
agency, on its face and as applied, which obviously involves state action. See
New York Times v. Sullivan, 376 U.S. 254 (1964).
Appellees correctly admit, [o]nly when a public official takes affirmative
steps to enforce those remedies does state action arise. AAB, p.42. The
Commissioner takes the affirmative steps of accepting Petitions for Controversy
for actions where there are no prohibition or penalty provisions in the statute
and stays any court actions by the talent representatives to enforce their
contractual rights. Then, if violations are found, the Commissioner voids

20
contracts and orders disgorgement, assigning remedies that must be
characterized as criminal, despite there being no criminality. The Commissioner
accepting controversies, holding hearings without basic protections such as the
right to discovery, to confront the accuser within a court of law, a decision
being made not bound by the judicially constructed rules regarding evidence
or civil procedure, and voiding contracts is inarguably state action interfering
with private commerce.
Appellees argue, even if procuring employment was protected expressive
conduct, the TAA would still pass muster because the states interest in
regulating talent agents, may give it concomitant interest in expression itself.
AAB, p.43, quoting Edenfield v. Fane, 507 U.S. 761 (1993). However,
Edenfield held that Floridas ban on direct, in-person, uninvited solicitation by
CPA's cannot be sustained under the First Amendment. Id. At 767. This has
absolutely nothing in common with the facts, circumstances or issues presented
in this matter.
Appellees ignore and do not address the four-prong test established by the
Supreme Court to measure the validity of restraints on commercial expression
despite state interests. AOB, pp.41-43. The reason for this conscious omission
is that any attempt to apply the aforementioned Supreme Court created test to
this matter would fail.

21
This Court should declare the TAA as written and enforced burdens and
restricts commercial speech in violation of the First Amendment and order the
District Court to enjoin the enforcement of the TAA.
D. APPELLEES DO NOT ADDRESS CLAIMS THAT THE TAA
VIOLATES THE COMMERCE CLAUSE
Appellant claims the TAA, facially and as applied, impedes the flow of
commercial trade across state lines, deprives out-of-state competitors from
equal access to the lucrative California talent market and directly burdens
interstate commerce; all in violation of the Commerce Clause. AOB, pp.30-39.
Appellees do not address any of Appellants following interstate commerce
claims:
(1) The TAA requires payment of a license fee for carrying on an occupation
engaged in interstate commerce, which burdens interstate commerce.
AOB, pp.36-37.
(2) The channels, instrumentalities and activities of Appellant have a
substantial effect on interstate commerce. AOB, pp.30-31.
(3) The TAA facially regulates commerce that takes place outside of
Californias borders. AOB, p.35.
(4) Unlicensed parties can enter Californias talent marketplace only by
involving an in-state licensee, economic protectionism discriminating in

22
favor of in-state interests over out-of-state competitors. AOB, p.35.
Appellees argue Appellants entire [Interstate Commerce] claim rests on
the premise that only persons who reside in California may obtain a talent
agents license and Appellant, cites no authority for this notion other than an
unwarranted inference from the fact where the statute requires a license to state
the licensees address, it omits to include the state of residence. AAB, pp.34-
35.
These arguments misrepresent the facts. Appellant cites the Commissions
website and the 719 listed TAA Licensees (as of October 1, 2013); none of
whom are wholly domiciled outside California. AOB, p.34. Appellees do not
contest Appellants claim that the handful of listed out of state licensees all
have California residency status. AOB, p.33.
Appellees fail to refute that the TAA requirement to use licensed agents
even when engaging in out-of-state commerce is protectionist and
unconstitutional. See AOB, p.38, where personal managers for The Platters and
Anita Baker lost their contractual rights for utilizing out-of-state agents to get
their clients work in Midwest venues and France, respectively.
Appellees fail to refute Appellants claim that the Commissioner lacks
Tenth Amendment authority to license occupations or premises located outside
of Californias borders. AOB, pp.31-32.

23
Appellees speak to the import of the entertainment industry to Californias
economy. AAB, p.44. Perhaps, but the Commerce Clause prohibits licensing
schemes from protecting a state or occupations economics, as the TAA does,
or payment of a license fee by in-state practitioners to engage in interstate
commerce. AOB, pp.36-37.
Nothing presented by Appellees moots the argument that the District Court
erred in finding Appellant did not state a plausible claim for a violation of
interstate commerce and that no amendment to the Complaint could cure any
pleading insufficiency. The Court should find the TAA on its face and as
applied is unconstitutional in violation of the Commerce Clause of the U.S.
Constitution, Art. I, Sec. 8.
E. APPELLEES FAILED TO ADDRESS CLAIMS THAT WITHOUT
A PENALTY PROVISION THE LABOR COMMISSIONER HAS
NO AUTHORITY TO USE THE TAA TO IMPAIR CONTRACTS
The AOB presented multiple authorities all concluding administrative
agencies cannot invent and mete out penalties without codified guidelines enacted
by the Legislature. AOB, pp.24-25.
Appellees argue because TAA disputes are civil, the cases cited by
Appellant are irrelevant as all concern the creation of crimes and penalties
imposed by government action. AAB, pg.24 fn.11. They also argue one of

24
Appellants authorities, BMW of America v. Gore, 517 U.S. 559, 574 (1995),
actually undermines Appellants argument. Id.
Once again Appellees misrepresent the facts. BMW is a civil matter. More
important, Appellees again provide only half of a citation; distorting its true
holding. They quote BMW to the effect that, strict constitutional safeguards
afforded to criminal defendants are not applicable to civil cases, (Id.) without
including the remainder of that sentence: but the basic protection against
'judgments without notice' afforded by the Due Process clause [citation] is
implicated by civil penalties. (Id.)
As the TAA contains no civil penalty, Appellees interpretation and
enforcement results in unconstitutional penalties without notice. Rather than
undermining Appellants argument, BMWs holding, that a person receive
fair notice not only of the conduct that will subject him to punishment but also
of the severity of the penalty that a State may impose, affirms Appellants
claim and establishes the Complaint should not have been dismissed with
prejudice. Id.
7

7
According to BPC 6068, attorneys may counsel or maintain those actions,
proceedings or defenses only as appear to him or her legal or just, and may never
seek to mislead the judge or any judicial officer by an artifice or false statement of
fact or law. Appellees have submitted several misleading statements. AAB,
p.3,8,19,24,27,33,35,39.

25
Appellees argument that the Legislature built in extraordinary due process
provisions into the TAA by allowing for de novo appeal to a superior court
(AAB, p.5) is groundless. It is analogous to arguing an arrest without probable
cause is not a civil rights violation because there are subsequent remedies for
police abuse. It is a civil rights violation to wrongfully arrest someone,
regardless of a subsequent appeal. Without the Legislature enacting any
prohibition or penalty in the TAA, the Commissioner violates the Constitution
the moment a controversy is accepted, which stays any efforts by the personal
manager to enforce his/her contractual rights.
Appellees argue a prohibition on assigning penalties, would thwart the
TAAs remedial purpose, to protect artists seeking professional employment
from the abuses of talent agencies. AAB, p.23. Even assuming the Legislature
did intend to keep improper people from becoming talent agents, exercising
authority to mete out penalties despite the Legislatures failure to create such
penalties finds no support in the law. According to United States v. Evans, 333
U.S. 483 (1948), assigning penalties is outside the bounds of judicial
interpretation, it is up to legislators to revise the statute than for [adjudicators]
to guess at the revision [a legislature] would make in determining the severity
of recourse. Id., p.495.

26
Appellees incorrectly argue the remedy of voiding contracts is a
straightforward application of the California Civil Code 1599 (the doctrine of
severability). AAB p.25. Adjudicators, including administrative agencies, only
consider severance after finding unlawfulness, which first requires prohibition
and penalty provisions within the TAA. Accepting 1599 as the remedy
provision for unlicensed procurement would be the epitome of accepting
unconstitutional vagueness.
8

F. APPELLEES FAILED TO ADDRESS CLAIMS THAT THE TAA
IMPAIRS THE OBLIGATIONS OF CONTRACTS IN
VIOLATION OF ARTICLE I, SECTION 10 OF THE U.S.
CONSTITUTION
Appellees enforcement of the TAA, from the moment a Petition of
Controversy is accepted, staying efforts to enforce an otherwise lawful contract,
violates Article I, Section 10 of the U.S. Constitution: No state shall enter into
any ex post facto Law, or Law impairing the Obligations of Contracts.
AOB, pp.43-46.
Appellees argue that this claim fails because, the contracts with which
appellant is concerned presumably arose after the 1985 enactment of the

8
Appellees spend pages arguing that applied challenges must focus on a specific
statute. Appellant cannot point to penalty or prohibition provisions that do not
exist. It is the enforcement of non-existent laws and the TAAs written gaps
Appellant is challenging.

27
TAA AAB, p.37. Appellant is challenging the enforcement of prohibitions
and sanctions that have never been enacted. The violation of the Contracts
Clause by Appellees application of the TAA has always violated the
Constitution, irrespective of whether it occurred before or after 1985. AOB,
p.44.
Both parties concur that the Contracts Clause does not protect illegal
contracts, which undermines Appellees citing of Crane v. Hahlo, 258 U.S. 142
(1922), using a quote that does not exist.
9
AAB, p. 37. Both parties also agree
the Contracts Clause protects legal contracts. As the TAA has neither
provisions authorizing impairing contracts nor provisions prohibiting
unlicensed procurement, 1700.4(a) only defines what talent agents do, the
TAA does not reserve any activities exclusively to licensees, the enforcement
clearly violates the Contracts Clause.
Appellees argue, the Contracts Clause is directed against impairment by
legislation, not by judgments of courts.
10
AAB, p.37, quoting Tidal Oil Co. v.
Flanagan, 263 U.S. 444, 451 (1923). Appellant is not challenging the judgment
of courts, but the enforcement of an administrative agency that wrongly results

9
The contract clause does not protect expectations that are based upon contracts
that are invalid, illegal, unenforceable, or which arise without the giving of
consideration.
10
The AAB said adjudication whereas the case itself says judgments of courts.

28
in an unsupportable interpretation of legislation. Appellee fails to cite any
legislation directing impairment exists and wholly ignores applicable case law
such as Wood, Bach, Loving, Severance, etc.
Appellees do not challenge Appellants claim that the TAA fails the three-
part test for whether a law conforms to the Contracts Clause. AOB, p.44
Further, it is undisputed that forfeitures are not favored in law when they result
in inequitable consequences and the rendering of services that benefit another
without compensation. AOB, p.45.
The Contracts Clause was codified to protect the rights of creditors:
The Contracts Clause was drafted and inserted into the
Constitution to prohibit states from passing debtor relief legislation
which had become, in the view of the Framers, an all-too-common
practice. The Contracts Clause was designed to prevent states
from retroactively eliminating or reducing the contractual rights of
creditors. Strang, Lee J., Federal Constitutional Law: Federalism
Limitations on State and Federal Power, Vol. 4 (2011).
Appellees enforcement is precisely what the Contracts Clause was
designed to prevent.
As Appellees offer no acceptable legal rationale to challenge Appellants
Contract Clause claims, this Court should declare the enforcement of the TAA
as applied violates Article I, Section 10 of the U.S. Constitution and enjoin its
enforcement.

29
G. APPELLEES IGNORED APPELLANTS CLAIMS THAT IN
VOIDING THE RIGHT TO COMPENSATION FOR LABOR
WITHOUT CLAIMS OF FRAUD OR NON-PERFORMANCE,
TAA ENFORCEMENT VIOLATES THE THIRTEENTH
AMENDMENT
Appellees state no opposition to Appellants claim that there are only three
ways that the right to compensation for labor expended can be disgorged:
claims of fraud, non-performance or when the labor itself is found to be
criminal. AOB, p.6.
Artists filing TAA controversies alleging unlicensed procurement do not,
as a rule, claim damages by fraud or non-performance. Instead they petition to
be excused from their contractual obligations solely because the service they
contracted for, benefitted from and agreed to pay for, in retrospect, was
allegedly unlawful.
According to Wood v. Krepps, licensing failures are questions between the
government and the person engaging in the regulated business, and the relevant
remedies are, not a matter in which third parties are interested. Whatever
penalties are imposed upon business delinquencies are not intended to
afford [the third party] an opportunity of repudiating indebtedness or acquiring
property without paying for it. Id., p.86. The Commissioners enforcement
does just that; wrongly affording artists opportunities to repudiate indebtedness
and past benefits without cost.

30
With no fraud or non-performance claims in Blancarte, the only
constitutional way Blancartes compensation could be forfeited would be if the
forfeiture was punishment for a criminal conviction. AOB, pp.9, 29. Forfeiture
of compensation for work that benefits others instead of leaving them less than
whole is axiomatically a criminal penalty. AOB, pp. 28-29.
The TAA controversy retroactively compelled attorney Blancarte through
legal process to have labored against his will in private business for the benefit
of another without conviction of a crime. He was subjected ex post facto to
involuntary servitude in violation of the Thirteenth Amendment. AOB, p.28.
Appellees incorrectly argue that because United States v. Kozminski, 487
U.S. 931 (1988) (AAB, p.33) referenced involuntary servitude [f]or purposes of
criminal prosecution, it has no bearing on Appellants civil action under 42
USC 1983. But as Appellees concede forfeiture of compensation for labor
without claims of fraud or non-performance is only appropriate after a criminal
conviction, they concede these prosecutions mete out criminal penalties.
Appellees argue, the fact plaintiffs members can choose not to manage
artists, or can avoid procuring employment for them, or can collaborate with a
licensed talent agency or simply get a license, takes this matter outside of the
Thirteenth Amendment.

31
Appellees concede personal managers serve as the entitys chief executive
officer who oversees the other talent representatives. AAB, pg.3.. The
CEOs objective is to maximize the quantity and quality of the artists
employment opportunities and it is what every artist signs up for. Staying arms-
length from the creation and maintenance of artist revenue is virtually
impossible. It is impossible for personal managers to find the line between
lawfully marketing their clients and unlawfully procuring employment.
Affirming the District Courts ruling would virtually outlaw personal
management, something entirely alien to the Legislatures intention and express
enactment.
If transactional attorneys obtain a talent agency license to negotiate artists
contracts, they become talent agents. Then if a separate talent agent, a non-
lawyer, procures an opportunity, the attorney either splits fees with the non-
lawyer in violation of Californias State Bar Act or works without
compensation, further reinforcing the finding of involuntary servitude. The
current enforcement creates a Hobsons choice where being compensated for
acting lawfully has become impossible; thus confirming the District Courts
ruling virtually outlaws entertainment transactional attorneys.

32
Involuntary servitude is to make labor free, by prohibiting that control by
which the personal service of one man is disposed of or coerced for another's
benefit. Bailey v. Alabama, 219 US 219, 241 (1911).
When the Commissioner allows artists to dispose of otherwise-lawful
compensation for services already provided, the personal manager is left having
provided services without compensation against his will. That is what makes
this a Thirteenth Amendment issue: Neither slavery nor involuntary servitude,
except as a punishment for crime whereof the party shall have been duly
convicted, shall exist within the United States.
H. THE DISTRICT COURT DID NOT CONSIDER THE
COMPLAINT IN ITS ENTIRETY
Appellant lists many issues in the Complaint that the District Court did not
consider, (AOB, pp. 46-47) including whether:
The TAA provides notice as to who is and what specific behavior is
regulated;
There is statutory and constitutional foundation for Appellees
enforcement without a specific statute restricting activity to licensees;
The voiding of compensation is a criminal remedy, since there are no
allegations of fraud or non-performance;
Any sanction without a codified penalty provision, be it fine or forfeiture,
is unlawful, unconstitutional, and

33
Appellees enforcement violates the rules of statutory construction.
The District Court left these questions unaddressed, thereby justifying
reinstating the Complaint.
I. APPELLEES FAIL TO ADDRESS OTHER CLAIMS
The AOB includes three pages of case law to buttress the claim that
District Court abused its discretion by denying leave to amend. AOB pp.9-11.
Appellees ignore this issue entirely, a concession that requires this matter to be
remanded.
AOB Section IX.A.4 claims the TAA As Applied Exceeds
Commissioners Statutory Authority. Appellees never once use the term
statutory authority, conceding there is none.
AOB Section IX.A.5 claims the Commissioner selectively enforces the
TAA, an issue Appellees do not contest. Nor do Appellees refute the Amicus
Letter claim that immunity is not available to any of Appellees because no
damages are sought. (Amicus Letter from Waisbren et al., pg. 7.)
Californias Constitution requires Appellees to defend their enforcement
until an appellate court finds it unconstitutional. A remand would require the
parties to return and make the same claims and defenses. In the interim,
personal managers would be left under this cloud of arbitrary and
unconstitutional enforcement.

34
III. CONCLUSION
Appellant requests that this Court find the TAA is facially and as applied
unconstitutional, violates the Contract and Interstate Commerce clauses, the
First Amendment, the Thirteenth Amendment and the Due Process and Equal
Protection provisions of the Fourteenth Amendment of the U.S. Constitution.
Appellant also requests injunctive relief; that this Court enjoin Appellees
from subjecting Appellant and other citizens to the deprivation of their rights,
privileges and immunities secured by the U.S. Constitution in violation of 42
USC 1983.
At the very minimum, Appellant requests this Court remand this matter to
the District Court for further proceedings, including amendment of the
Complaint.
Dated: January 16, 2014

By /s/ Stephen F. Rohde
STEPHEN F. ROHDE
STEPHEN F. ROHDE (SBN 51446)
LAW OFFICES OF STEPHEN F. ROHDE
1801 Century Park East, Suite 240
Los Angeles, CA 90067
Tel: (310) 277-1482 Fax: (310) 772-0405

By /s/ Ryan H. Fowler
RYAN H. FOWLER
By /s/ Christopher B. Good
CHRISTOPHER B. GOOD


35
By /s/ Frank W. Ferguson II
FRANK W. FERGUSON II
RYAN H. FOWLER (SBN 227729)
CHRISTOPHER B. GOOD (SBN 232722)
FRANK W. FERGUSON II (SBN 211694)
FOWLER & GOOD LLP
15303 Ventura Blvd., 9th Floor
Sherman Oaks, CA 91403
Tel: (818) 302-3480 Fax: (818)279-2436

Attorneys for Appellant
National Conference of Personal Managers Inc.

36
CERTIFICATE OF COMPLIANCE
I hereby certify that this brief does not exceed the type-volume limitation
imposed by Federal Rules of Appellate Procedure 32(a)(7)(B). The brief was
prepared using Microsoft Word 2010 and contains 6,989 words of proportionally
spaced text. The typeface is Times New Roman, 14-point font.
STEPHEN F. ROHDE
Tel: (310) 277-1482 Fax: (310) 772-0405

RYAN H. FOWLER
CHRISTOPHER B. GOOD
FOWLER & GOOD LLP
Tel: (818) 302-3480 Fax: (818)279-2436



37
CERTIFICATE OF SERVICE
I hereby certify that I electronically filed the foregoing Reply Brief for
Appellant with the Clerk of the Court for the United States Court of Appeals for
the Ninth Circuit by using the appellate CM/ECF system on January 16, 2014. All
persons who are required to be served are registered CM/ECF users, who will be
served by the appellate CM/ECF system.

STEPHEN F. ROHDE
Tel: (310) 277-1482 Fax: (310) 772-0405

RYAN H. FOWLER
CHRISTOPHER B. GOOD
FOWLER & GOOD LLP
Tel: (818) 302-3480 Fax: (818)279-2436



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