BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                     SB 588


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           Date of Hearing:   July 14, 2015


                           ASSEMBLY COMMITTEE ON JUDICIARY


                                  Mark Stone, Chair


          SB  
          588 (De León) - As Amended July 1, 2015


          SENATE VOTE:  26-13


          SUBJECT:  nonpayment of wages: Labor Commissioner and  judgment  
          enforcement


          KEY ISSUES: 


          1)should the labor commissioner, on behalf of an aggrieved  
            employee, be authorized to file a levy against any credits,  
            MONEY, or other property of an employer in order to collect a  
            judgment for unpaid wages?  


          2)If an employer fails to satisfy a judgment within 20 days of  
            receiving a notice of levy, should that employer be required  
            to cease business operations or obtain a surety bond of  
            $150,000? 


          3)Should a business that contracts for certain "Property  
            services" be jointly and severally liable for the wage  
            violations of the service contractor, so long as the business  
            was named and noticed in the underlying compLaint?  








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                                      SYNOPSIS


          According to a 2010 study conducted jointly by the UCLA Labor  
          Center and the National Employment Law Project, only 17% of  
          workers who successfully filed a wage claim with the California  
          Division of Labor Standards recovered any payment.  SB 588 is  
          one of several recent bills that have sought to deal with the  
          problem of collecting unpaid wages, even where a court has found  
          a violation and the employee has won a judgment against an  
          employer.  Most recently AB 1164 (Lowenthal, 2013) and AB 2416  
          (Stone, 2014) attempted to grapple with this problem by allowing  
          an employee to file a "pre-judgment" lien against the real and  
          personal property of an offending employer.  Neither bill made  
          it to the Governor's desk.  The bill under review differs from  
          those bills in two significant ways.  First, this bill  
          authorizes not a lien against real property, but a levy against  
          the employer's credit, money, or related property (other than  
          real property).  A lien is authorized only where the employer  
          fails to satisfy a judgment after notice of judgment and  
          continues to operate without complying with a specified bond  
          requirement.  Second, and perhaps most significantly, this bill  
          does not authorize a pre-judgment lien; rather, it authorizes  
          the levy or lien to be filed only where a judgment has already  
          been rendered against the employer.  Although a coalition of  
          business and employer groups, led by the Chamber of Commerce,  
          opposed the prior bills, the same coalition has submitted only a  
          letter of "concern" regarding this bill.  When the bill recently  
          passed out the Assembly Labor & Employment Committee, the author  
          and the Chamber of Commerce indicated a willingness to work on  
          the remaining issues.  However, no agreement had been reached at  
          the time of the writing of this analysis.  The analysis  
          discusses the three issues on which the coalition and author  
          still disagree; however, amendments, if any, would occur in the  
          Appropriations Committee, or on the Floor, if the bill passes  
          out of this Committee. 









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          SUMMARY:  Authorizes the California Labor Commissioner  
          (Commissioner) to file a levy, and in some cases, a lien on an  
          employer's property in order to assist an employee in enforcing  
          a judgment for unpaid wages.  Specifically, this bill:  


          1)Allows the Commissioner, after a judgment for unpaid wages is  
            entered by a court in favor of the Commissioner or employee,  
            to mail a notice of levy to all persons who possess or control  
            any credits, money, or property belonging to the employer.   
            Requires any person upon whom a levy has been noticed to  
            surrender the credits, money, or property to the Commissioner,  
            or pay to the Commissioner the amount owed, within ten days of  
            service.  

          2)Provides that a person who complies with the notice of levy  
            shall be discharged from any obligation or liability to the  
            employer.  Any person who fails or refuses to surrender any  
            credits, money, or property, or pay any debts owed, shall be  
            liable to the Commissioner in an amount equal to the levy.

          3)Exempts real property from the provisions above.

          4)Provides, subject to exceptions, that if a final judgment  
            against an employer for unpaid wages remains unsatisfied for  
            20 days after the time to appeal the judgment has expired and  
            no appeal is pending, then the employer must cease business  
            operations unless the employer has obtained a surety bond of  
            $150,000.  The bond must be filed with the Commissioner and  
            paid to the people of the State of California for the benefit  
            of the aggrieved employee.

          5)Subjects any employer, or person acting on behalf of an  
            employer, that violates the bond requirement to a civil  
            penalty, as specified, and a "stop order" prohibiting the  
            conduct of business until the employer complies with the bond  
            requirements.  









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          6)Authorizes the Commissioner, in the event that the employer  
            fails to comply with the bond provision, to impose a lien on  
            the employer's real and personal property for the full amount  
            of wages, interest, penalties, and attorney's fees, to the  
            extent allowed under law. Unless it is satisfied or released,  
            the lien remains in place for ten years from the date of its  
            creation. 

          7)Prohibits the State Department of Public Health or the State  
            Department of Social Services from renewing the license of an  
            employer in the long-term care industry, as defined, if the  
            employer is conducting business in violation of the surety  
            bond requirement. 

          8)Provides that an individual or business that contracts with an  
            employer to perform property services or long-term care  
            services shall be jointly and severally liable with the  
            employer for unpaid wages if the business was named as a  
            defendant in, and received notice of, the underlying  
            complaint. 

          9)Requires property services and long-term care contractors to  
            provide notice to the other party to the contract as to any  
            outstanding wage violations or unsatisfied judgments, but also  
            states that the failure by the employer to provide such  
            notices shall not be a defense to the joint and several  
            liability.

          10)Creates enforcement provisions for liens and levies discussed  
            above within the Code of Civil Procedure.  These provisions  
            would bestow jurisdiction on the superior court and detail the  
            service and hearing requirements for levies and liens filed by  
            the Labor Commissioner.

          EXISTING LAW:   


          1)Gives mechanics, persons furnishing materials, artisans, and  
            laborers of every class the right to file a lien against the  








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            property upon which they have bestowed labor or furnished  
            material for the value of such labor and material.  Existing  
            law also requires the Legislature to provide, by law, for the  
            speedy and efficient enforcement of such liens.  (California  
            Constitution Article XIV, Section 3.)

          2)Provides for mechanics liens relating to labor, services, and  
            supplies provided to a work of improvement and regulates the  
            conditions under which a mechanics lien may be enforced.   
            (Civil Code Sections 8400-8494.)

          3)Recognizes prejudgment wage liens against property as a remedy  
            in certain industries, including mining (Civil Code Section  
            3060), agriculture (Civil Code Sections 3061.5-3061.6), and  
            logging (Civil Code Section 3065).

          4)Authorizes the Commissioner, after investigation and upon  
            determination that wages or monetary benefits are due and  
            unpaid to any worker in the State of California, to collect  
            such wages or benefits on behalf of the worker without  
            assignment of such wages or benefits to the Commissioner.   
            (Labor Code Section 96.7.)

          5)Authorizes the Commissioner to investigate employee complaints  
            and provide for a hearing in any action to recover wages,  
            penalties, and other demands for compensation, and requires  
            the Commission to determine all matters arising under his or  
            her jurisdiction.  (Labor Code Section 98.)

          6)Authorizes the Commissioner, at its discretion and upon a  
            final order, to place a lien on real property for amounts due  
            under the final order and in favor of the employee or  
            employees named in the order, with the county recorder of any  
            county in which the employer's real property may be located.   
            (Labor Code Section 98.2(g).)

          7)Provides that, if any employer or other person acting on  
            behalf of an employer violates, or causes to be violated, any  
            provision regulating hours and days of work in either statute  








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            or regulation shall be subject to a civil penalty.  (Labor  
            Code Section 558.)

          FISCAL EFFECT:  As currently in print this bill is keyed fiscal.


          COMMENTS:  Recent studies have highlighted the problem of unpaid  
          wages in California and elsewhere.  For example, a 2009 Ford  
          Foundation study on workers in low-wage industries in Chicago,  
          Los Angeles and New York City found that 26 percent of workers  
          in the sample were paid less than the legally required minimum  
          wage, and 60 percent of these workers were underpaid by more  
          than $1 per hour.  In addition, 76 percent of the respondents  
          who worked overtime in the previous week were not paid the  
          legally required overtime rate by their employers.  Another  
          survey of 1,815 workers in Los Angeles County found that  
          low-wage workers regularly experience violations of minimum wage  
          and overtime pay requirements.  (Center for Urban Economic  
          Development, National Employment Law Project, UCLA Institute for  
          Research on Labor and Employment Broken Laws, Unprotected  
          Workers: Violations of Employment and Labor Laws in America's  
          Cities (2009); Milkman, Gonzalez and Narro, Wage Theft and  
          Workplace Violation in Los Angeles: The Failure of Employment  
          and Labor Law for Low-Wage Workers, UCLA Institute for Research  
          on Labor and Employment (2010).)  


          The Problem of Collecting Unpaid Wages.  While the number of  
          violations is bad enough, the statistics on the inability of  
          workers to recover wages - even when a court or the Labor  
          Commission issues a judgment in their favor - are staggering.   
          Under existing law, when an employer fails to pay wages that are  
          due, the employee has the right to file a claim against the  
          employer with the Department of Labor Standards Enforcement  
          (DLSE), which is directed by the State Labor Commissioner  
          (Commissioner).  After conducting an investigation, the  
          Commissioner typically holds an administrative hearing and  
          renders a decision.  If either party is unhappy with the  
          Commissioner's decision, it can bring an appeal in civil court.   








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          However, even where a worker wins a favorable decision, the  
          process of collecting the award is often difficult and  
          ineffective.  Irresponsible employers may have hidden their cash  
          assets, declared bankruptcy, or otherwise become judgment-proof.  
            According to a 2013 report published by the National  
          Employment Law Project (NELP) and the UCLA Labor Center, only  
          17% of workers who prevailed in their wage claim before the DLSE  
          and won a judgment were able to receive any payment between 2008  
          and 2011.  


          Comparison with Prior Bills.  SB 588 seeks to address the  
          problem of unpaid wages by giving the Commissioner expanded  
          power to file a levy or lien against the property of an  
          employer.  It is the latest in a series of recent bills that  
          have sought to deal with the problem of collecting unpaid wages  
          from employers after a court has found a violation and the  
          employee has won a judgment against the employer.  Most recently  
          AB 1164 (Lowenthal, 2013) and AB 2416 (Stone, 2014) attempted to  
          grapple with this problem by allowing an employee to file a  
          "pre-judgment" lien against the real and personal property of  
          the offending employer.  Both of these bills faced considerable  
          opposition from business and employer groups.  AB 1164 died on  
          the Assembly Floor; AB 2416 passed out of the Assembly only to  
          die on the Senate Floor.  The bill under review differs in three  
          important ways from those prior bills.  First, this bill  
          authorizes not a lien against real property, but a levy against  
          the employer's credit, money, or related property that is not  
          real property.  Under this bill, a lien against real property is  
          authorized only where the employer fails to satisfy a judgment  
          after notice of judgment and continues to operate without  
          complying with the bond requirement, as described below.   
          Second, this bill authorizes the Commissioner to file a levy or  
          lien on the employee's behalf; unlike the earlier bills, this  
          bill does not allow an employee to directly file a lien against  
          an employer's property.  Third, and perhaps most significantly,  
          this bill does not authorize a pre-judgment lien; rather, it  
          authorized the levy or lien to be filed only where a judgment  
          has already been rendered against the employer.  








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          Changes to Existing Law.  California's "mechanic's lien" law -  
          as required by the California Constitution - gives mechanics,  
          artisans, suppliers, and "laborers of every class" a lien  
          against any property "upon which they bestowed labor or  
          furnished material for the value of such labor done and material  
          furnished."  (California Constitution Article XIV, Section;  
          enacted and enforced by Civil Code Sections 8400-8494.)  Because  
          the labor or materials of a worker are bestowed upon a  
          "property," this provision has generally been construed to apply  
          to works of improvement.  For example, a worker who installs  
          windows on a new building has a lien for the value of his or her  
          labor against the building property.  If that worker is not paid  
          for her labor, she can try to collect by recording a lien  
          against the property.  However, an employee who merely works in  
          an office, factory, or department store has no ability to file  
          such a lien against the employer's property if the employer  
          fails to pay proper wages.  That worker would most likely file a  
          claim for unpaid wages with the Commissioner and hope to win a  
          judgment against the employer.  Upon receiving a claim from an  
          employee, the Commissioner has the authority to investigate the  
          claim, conduct a hearing, and, if it determines that wages or  
          other monetary benefits are due, collect wages or benefits on  
          behalf of the worker.  Finally, under existing law, the  
          Commissioner may, upon issuing a final order, place a lien on  
          the employer's real property for the amount of unpaid wages that  
          are due. 


          Bill Expands Labor Commission's Existing Authority.  This bill  
          would expand the Commissioner's existing authority to collect  
          unpaid wages in two important ways:  


          First, while the Commissioner could still record a lien against  
          the real property of an employer who did not satisfy a final  
          order, this bill would give the Commissioner the additional  
          authority to collect a court judgment in favor of the  








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          Commissioner or any employee by mailing a "notice of levy" to  
          all persons in possession of credits, money, or other property  
          (other than real property) belonging to the employer.  A levy is  
          similar to, but not the same as, a lien.  A lien is a recorded  
          interest or encumbrance on real property, which can be collected  
          upon sale of the property.  A levy, on the other hand, is simply  
          a legal means to seize the money or assets of a judgment debtor.  
           It can be directed, for example, to a bank or other party in  
          possession of the debtor's money or assets.  Under this bill, if  
          a person in possession of the debtor's money fails to surrender  
          the money, that person is liable to the Commissioner for the  
          amount of the levy.  If the person in possession surrenders the  
          money, that person is discharged from any obligation or  
          liability to the employer.


          Second, where a final judgment against an employer remains  
          unsatisfied for 20 days after the time for an appeal has expired  
          (and no appeal is pending), this bill would prohibit the  
          employer from conducting business in this state unless the  
          employer obtains a surety bond in the amount of $150,000.  The  
          bond must be filed with the Commissioner and paid to the state  
          for the benefit of the employee who is denied his or her just  
          wages.  If the employer fails to comply with the bond  
          requirement, this bill would give the Commissioner the authority  
          to serve upon that employer a "stop order," prohibiting the  
          employer from using any employee labor or continuing to operate  
          by subcontracting for labor.  (In theory, the employer could  
          continue to operate the business if he did the work himself, but  
          as a practical matter the stop order is an order to cease  
          operations until judgments are paid or appropriate bonds  
          acquired.)  An employer, or any officer or manager of the  
          employer having effective control of the operation, who  
          continues to operate the business in the face of the stop order,  
          commits a misdemeanor punishable by imprisonment in county jail  
          for not more than 60 days or by fine not exceeding $10,000, or  
          both.  The Commissioner may also record a lien against the real  
          property of any employer who violates the bond requirement.









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          Potential Liability of Supervisors and Managers.  In addition to  
          expanding the authority of the Commissioner to file levies and  
          enforce the new bond requirement, this bill also expands  
          existing law in other ways.  Under existing law, the  
          Commissioner may issue citations and impose fines for violating  
          wage laws against the employer or any "other person acting on  
          behalf of an employer who violates or causes to be violated" the  
          wage law provisions.  This bill, however, appears to use more  
          expansive language by allowing the Commissioner to conduct  
          hearings concerning wage violations against any employer "or  
          other person acting on the employer's behalf."  One of the  
          concerns expressed by the Chamber of Commerce is that this new  
          language omits the critical words "who violates or causes to be  
          violated."  In other words, the Chamber contends, this new  
          language could subject a manager, or even a relatively low-level  
          employee, to penalties whether or not the manager or employee  
          had sufficient control to commit or prevent a violation.  (The  
          Chamber's proposed resolution to this issue is discussed below.)


          Joint and Several Liability of Contracting Parties.  This bill  
          also appears to expand existing law by imposing joint and  
          several liability for wage violations on any business that  
          contracts with an offending employer to perform "property  
          services" or "long-term care services," but only where the  
          business was named as a defendant and received notice pursuant  
          to a complaint filed with the Commissioner.  ("Property  
          services" is defined to mean janitorial, security guard, valet  
          parking, landscaping and gardening services; "long-term care  
          services" is defined to mean a skilled nursing facility, adult  
          residential facility, and residential care facility for the  
          elderly and related facilities.)  The bill requires an employer  
          who contracts to provide those services to inform the other  
          party to the contract of any pending claims or unsatisfied  
          judgments for non-payment of wages.  However, the bill also adds  
          that an employer's failure to provide that information to the  
          other party will not be a defense to the joint and several  
          liability created by this bill.  The Chamber of Commerce and its  








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          coalition express serious concerns about this provision,  
          contending that it unfairly makes a business liable for  
          violations committed by other employers over whom they may have  
          little or no control.  However, the rationale for this  
          provision, according to the author, is that a business that uses  
          such services has some obligation to take reasonable steps to  
          ensure that the company with which it contracts does not exploit  
          or cheat its workers.  As noted below, this provision continues  
          to be a considerable source of disagreement between the author  
          and the concerned business coalition.   




          Remaining Concerns among Business Groups.  A coalition of  
          business and employer associations, led by the California  
          Chamber of Commerce, expresses "concerns" that certain  
          provisions of this bill will negatively impact employers.   
          First, the coalition argues that the joint and several liability  
          provisions are unfair because a business should not be penalized  
          for the actions of a company with which it happened to contract  
          but, through no fault or control or the contracting party,  
          failed to pay the wages owed to its workers.  Second, the  
          coalition argues that this bill could improperly impose personal  
          liability on lower-level supervisors and managers for wage and  
          hour violations they did not commit and could not have  
          prevented.  Finally, the coalition argues that the amount of the  
          proposed bond needs to be adjusted to encourage payment of the  
          underlying judgment.  The coalition suggests that the amount of  
          the bond should be left to the discretion of the Commissioner,  
          allowing the Commissioner to take into account the "totality of  
          circumstances" in setting a proper and reasonable bond amount.   
          To address these issues, the concerned business and employer  
                 coalition has proposed, conceptually at least, three possible  
          amendments that might address their concerns: 


           In place of the fixed bond amount of $150,000, the Chamber of  
            Commerce proposes either (1) a tiered bond amount based on the  








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            "totality of circumstances" or (2) giving the Labor  
            Commissioner the discretion to determine an appropriate bond  
            amount, up to $150,000. 


           In order to ensure that the bill does not improperly impose  
            liability on managers or employees because of the employers'  
            violation, the Chamber of Commerce proposes adding language  
            that tracks the general rule of existing case law that a  
            manager or other employee may only be liable for a violation  
            if the manager or employee had sufficient control to cause the  
            violation.  Therefore, the Chamber of Commerce proposes adding  
            the following qualifying language (or something like it):   
            Liability under this section shall not apply if the person was  
            acting solely within the scope of their agency with the  
            employer and lacked any personal or direct control over the  
            working conditions or payment of wages to the employee. 


           Modify the joint and several liability provisions so that a  
            business that contracts with an employer who violates wage  
            laws has an "opportunity to cure" the violation.  Under this  
            bill, a business would only be jointly and severally liable  
            for the employer's violations if the business were named as a  
            defendant and given notice at the time that a complaint was  
            filed with the Labor Commission.  It is not entirely clear to  
            the Committee what the "opportunity to cure" would consist of,  
            given that the business would only receive notice after the  
            complaint had been filed and thus a violation has already  
            committed.  The businesses ability to cure would seem to be  
            limited to its ability to force the employer with whom it  
            contracts to satisfy the unpaid wages or face termination of  
            the contract.  This may be an issue that the author and  
            opponents are unlikely to resolve. 

          The Committee may wish to explore with the author his  
          willingness to address all or some of these concerns should the  
          bill pass out of this Committee today.









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          ARGUMENTS IN SUPPORT:  Supporters, noting the various wage theft  
          studies, argue that wage theft is a significant problem in  
          California, with LA County's wage theft resulting in over $1  
          billion failing to reach the workers who desperately need and  
          are lawfully entitled to those wages.  Supporters also note that  
          current wage theft collection rates are less than 20%, meaning  
          the vast majority of scofflaw employers are successful in  
          robbing their workers of their lawful wages.  Supporters believe  
          that this bill will help combat the high rate of wage theft in  
          California by creating a simple lien process for the Labor  
          Commissioner to use against employers who rob workers of their  
          wages.  Supporters, noting Wisconsin's success, argue that wage  
          liens are simple, effective, and a time tested approach to  
          halting wage theft.




          This bill is co-sponsored by the Service Employees International  
          Union, the Koreatown Immigrant Workers Alliance, and the Wage  
          Justice Center.  They argue that SB 558 "gives the Labor  
          Commissioner additional tools to collect from employers who have  
          exhausted all appeals for their non-payment of wages and have  
          final judgments owed.  It requires a business that has an  
          outstanding unpaid judgment against them to purchase a wage bond  
          of $150,000.  If it fails to do that, the employer can be  
          subject to a stop work order and a lien at the Labor  
          Commissioner's discretion.  . . This bill also gives the Labor  
          Commissioner the authority to hold individual business owners  
          accountable for their debts to workers.  This will discourage  
          business owners from rolling up their operations and walking  
          away from their debts to workers and starting a new company."   
          Finally supporters contend that this bill will target "two  
          high-risk sectors - property services and long-term care - by  
          establishing procedures to ensure parties are held individually  
          responsible to ensure that employers can't evade the law through  
          contracting and subcontracting arrangements."










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          REGISTERED SUPPORT / OPPOSITION:




          Support


          Koreatown Immigrant Workers Alliance (co-sponsor)


          SEIU- CA (co-sponsor)


          Wage Justice Center (co-sponsor)


          9to5


          Alliance of Californians for Community Empowerment


          Alliance San Diego


          Asian Americans Advancing Justice- Los Angeles


          Bet Tzedek Legal Services


          California Employment Lawyers Association


          California Immigrant Policy Center


          California Labor Federation, AFL-CIO








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          California Professional Firefighters


          California Rural Legal Assistance


          California School Employees Association


          Center on Policy Initiatives


          Central American Resource Center


          Centro Legal de la Raza


          Chinese Progressive Association


          CHIRLA-Coalition for Humane Immigrant Rights of Los Angeles


          CLEAN Car Wash Campaign


          Clergy and Laity United for Economic Justice


          Coalition For A Safe Environment


          Coalition to Abolish Slavery & Trafficking


          Community Action Board of Santa Cruz County Inc.








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          Community Services


          Day Labor Center Hayward/ Oakland


          Day Worker Center of Mountain View


          Dignity Campaign


          Dolores Street Community Services


          Employment Rights Center


          Equal Rights Advocates


          Filipino Advocates for Justice


          Filipino Migrant Center


          Fresno County Democrats


          Garment Worker Center


          Gender Justice LA


          Graton Day Labor Center








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          Holman United Methodist Church


          Housing Long Beach


          Human Impact Partners


          InnerCity Struggle


          Instituto de Educacion Popular del Sur de California


          Katharine & George Alexander Community Law Center


          Khmer Girls in Action


          LA Black Worker Center


          La Colectiva De Mujeres


          Liberty Hill Foundation


          Los Angeles Alliance for a New Economy


          Los Angeles Fight for $15 Organizing Committee


          Maintenance Cooperation Trust Fund








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          Making Change at Walmart


          Mi Familia Vota


          National Association of Working Women


          National Day Laborer Organizing Network


          National Employment Law Project


          One LA-IAF


          Pacoima Beautiful


          Pilgrim United Church of Christ


          Pilipino Association of Workers and Immigrants - Silicon Valley


          Restaurant Opportunities Center of Los Angeles


          Sacramento Area Congregations Together


          San Diego and Imperial Counties Labor Council, AFL-CIO


          San Francisco Day Labor Program & Women's Collective, a program  








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          of Dolores Street


          San Francisco Progressive Workers Alliance


          Santa Clara University


          SoCalCosh, Southern California Coalition for Occupational Safety  
          and Health


          Social Justice Learning Institute


          Street Level Health Project


          T.R.U.S.T. South LA


          The Institute of Popular Education of Southern California


          The Wage Justice Center


          UCLA Labor Center


          Union de Vecinos


          Workplace Justice Initiative


          Worksafe, Inc.









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          Opposition


          None on file




          Analysis Prepared by:Thomas Clark / JUD. / (916)  
          319-2334