Monday, November 26, 2012

Charlie Sheen & The Employment Conundrum: Good Faith, Arbitration and the Contract by Mahmoud Fadli

Charlie Sheen & The Employment Conundrum: Good Faith, Arbitration and the Contract
By Mahmoud Fadli

Employment law is an expanding and ever fluid field of law. It affects the each and every one of us, often without our realization. From factory workers to high-ranking fortune five hundred chief executive officers, employment law and its principles reign supreme in the American job market. It is thus no surprise that even the most famous of actors are not immune from this body of law. In fact, some of the most interesting, and sometimes entertaining, disputes come from Hollywood. From celebrity divorces to celebrity breakdowns, the media is constantly on the prowl for the latest, and hottest gossip. This time, the media has stumbled upon something worth nothing: the rise and continuing fall of an American actor and the fate of his employment contract; of course, this refers to Mr. Charlie Sheen.

This paper will familiarize the reader with the background to the dispute between Charlie Sheen, Warner Brothers Television, Three and a Half Men producer Chuck Lorre and Lorre Productions. Facts and dates will be stated and based off of various press releases, reports, letters between counsel for the three parties, and legal briefs filed in court.[1] Then, the paper will discuss the standard for just cause termination, the legal concept which Warner Brothers and Chuck Lorre et. al. use to justify Mr. Sheen’s termination. The paper will look at the merits of the claims under the law as stated in the casebook assigned to this class and then predict the likely outcome of the claim.[2] Next, the paper will discuss the advantages and disadvantages of employment arbitration, referencing the employment contract between Mr. Sheen and Warner Brothers and Chuck Lorre et. al. and predicting both the outcome of arbitration and which party benefits particularly from the arbitration. Finally, the paper will discuss the remaining possible justifications for terminating the agreement between Mr. Sheen, Warner Brothers, and Mr. Lorre et. al.

The Dispute & The Necessary Facts

This section will outline that dispute itself, providing a chronological ordering of necessary facts that will be important in the subsequent sections of this paper. This section is intended to be comprehensive, and will follow the letters exchanged by counsel, the legal briefs and media reports that form the narrative for this dispute. The show in question, Two and a Half Men, is a prime time CBS Sit-Com “about men, women, sex, dating, divorce, mothers, single parenthood, sibling relations, surrogate families, money and, most importantly, love.”[3] The show’s cast plays a number of interesting and comical characters. Specifically, Charlie Sheen plays Charlie Harper, “a well-to-do bachelor with a house at the beach, a Mercedes in the garage and an easy way with women.”[4] The show is a popular hit, with Sheen’s character, along with the other cast members, making for a memorable and comedic depiction of life for this rather dysfunctional family.

However, not all things were as comical and entertaining in reality. Mr. Sheen had been in the press on and off, with stories of wild parties, extreme drug use and misbehavior spreading throughout the airwaves. As a result, on March 8, 2011, representatives for the popular American television show “Two and a Half Men” announced that the contract pertaining to Mr. Sheen’s involvement in the show would be terminated “effective immediately,” resulting in the cancellation of the remaining episodes of the show.[5] As a result, Mr. Sheen has been giving “manic” and “rambling” interviews to the press, often times insulting and degrading the show’s producers and sponsors.[6] While it came as a surprise to the public, the dispute was long in the making. A few days prior, on February 28, 2011, attorney’s for Mr. Sheen sent a letter to Warner Brother’s Television (hereinafter the “February 28 Letter”). The February 28 Letter pertained to a February 24 statement by Warner Brothers announcing that “based on the totality of Charlie Sheen’s statements, conduct and condition, CBS and Warner Brothers Television have decided to discontinue production of Two and a Half Men for the remainder of the season.”[7]

The February 28 Letter asserted that Mr. Sheen was “clean and sober,” and that he was ready and willing to perform under his contractual obligations to Warner Brothers.[8] The letter accused the show’s producer, Chuck Lorre, of disseminating “outrageous insults and derogatory remarks targeting [Mr. Sheen] in vanity cards” at the end of Mr. Lorre’s shows.[9] The February 28 latter also asserted that Mr. Sheen’s remarks against Mr. Lorre were simply retaliation to “Mr. Lorre’s unrelenting derogatory statements…”[10] Moreover, the February 28 Letter accuses Mr. Lorre of arranging to terminate the production of the series for the remainder of the season as retaliation for Mr. Sheen’s reaction.[11] Mr. Sheen’s counsel also claimed that he is a “third-party beneficiary of the agreement” between Warner Brothers and Mr. Lorre, and that it was Mr. Lorre who was in breach of the agreement by “refusing to render services through the contract season.”[12]

Finally, the February 28 Letter alleges that Warner Brothers and Mr. Lorre have employed a “double standard,” allowing Mr. Lorre to publicly bash Mr. Sheen while punishing Mr. Sheen for his reactions. The Letter ended with a demand for eight additional episodes of the series in order to Mr. Lorre and Warner Brothers to fulfill their contractual obligations to Mr. Sheen.[13]

Then, on March 7, 2011, one day prior to Reuters reporting the announcement by Warner Brothers and CBS, counsel for Warner Brothers sent an eleven-page response to Mr. Sheen outlining, in detail, Mr. Sheen’s outrageous behavior (hereinafter the March 7 Letter). The March 7 Letter states that Mr. Sheen has been “engaged in dangerously self destructive conduct” and appears to be “very ill.”[14] The letter notes Mr. Sheen’s “declining condition,” alleging that it “undermined the production in numerous and significant ways.”[15] According to the letter, Warner Brothers, CBS and Mr. Lorre have “done everything within their power to get Mr. Sheen the help he so badly and obviously needs,” including assisting Mr. Sheen enter rehabilitation for his drug addition.[16]

Specifically, the March 7, 2011 Letter categorizes Mr. Sheen’s conduct. The letter notes the extremely “public divorce from Denise Richards and the resulting inflammatory court documents” filed in that regard.[17] Next, the letter notes the Aspen incident in December 2009[18] and the Plaza Hotel incident in October 2010[19]. The letter continues, stating that the “situation took a dramatic turn for the worse in January and February” of 2011, where Mr. Sheen’s conduct and condition prevented him from doing his duties.[20] Specifically, according to the letter, in January 2011 Mr. Sheen went on “at least” one trip to Las Vegas, allegedly consuming “substantial amounts” of cocaine and alcohol.[21] The letter cites press reports stating that the trip was a “three-day bender,” noting Mr. Sheen “was seen drinking the morning of his return,” which was the “same day he was scheduled to begin rehearsing that weeks’ episode of the show.”[22] The letter also noted that Mr. Sheen was late to that particular rehearsal, and missed the subsequent rehearsal “entirely” the next day.[23]

Next, the letter notes press reports about Mr. Sheen being rushed to the hospital on January 27, 2011 after having a “marathon party” that lasted “two days straight.”[24] Those same press reports indicate that a “briefcase full of cocaine had been delivered to Mr. Sheen’s home,” and that in a recent interview, he stated that the last time he used drugs, he “probably took more than anybody could survive.”[25] The concern, according to the March 7 Letter, for Mr. Sheen’s health was so great that Bruce Rosenblum, the President of Warner Brothers and Leslie Moonves, the President and CEO of CBS, personally “visited Mr. Sheen in his home on January 28, just after he left the hospital.”[26] The letter alleges that they both told Mr. Sheen that they were “profoundly concerned for his health, safety and well-being,” and that he “could not continue on this path.”[27] The next day, Mr. Sheen agreed that he would enter a rehabilitation facility.[28]

After refusing to leave his home for treatment, Mr. Sheen fired his “sobriety coach,” claiming that he had “self-healed his addictions by saying that he ‘blinked and cured [his] brain.’”[29] Then, on February 24, 2011, Mr. Sheen traveled to the Bahamas where he called into a radio show and “exhibited conduct that made it clear he was in no condition to perform his duties as the comedic lead in the Show.”[30] While many of his statements were bizarre,[31] Mr. Sheen stated, most embarrassingly, that Thomas Jefferson was a “pussy,” and that women invited to his house were “turds.”[32]

            The ranting did not stop there, according to the letter. That same day, Mr. Sheen attacked Mr. Lorre personally, calling him a “stupid, stupid little man and a pussy punk,” a “piece of shit,” “turd” and “clown.”[33] Mr. Sheen also stated that he “violently hates” Mr. Lorre, publicly challenging Mr. Lorre to “fight him in the ‘octagon.’”[34] As a result, on February 28, 2011, Warner Brothers sent Mr. Sheen a “notice of suspension” and requested that Mr. Sheen propose a cure for his condition, which “necessitated the suspension.”[35] When Mr. Sheen gave no proposal, Warner Brothers announced the cancellation. Thereafter, on March 10, 2011, Mr. Sheen’s attorneys filed suit against Warner Brothers, Chuck Lorre and Chuck Lorre Productions in the Superior Court of the County of Los Angeles’ Western District.[36]

Just Cause

            The general presumption is that employees are considered at-will.[37] Like all presumptions, however, this can be rebutted.[38] The “at-will” concept stems from private ordering, essentially allowing either one of the parties to terminate the agreement for any reason or no reason at all. This, however, is not the case for contracts that specify a term of employment.[39] This, however, becomes a question of fact that must be decided by a jury.[40] It is assumed that in this particular case, Mr. Sheen was hired to be an employee for the duration of the various seasons for Three and a Half Men. For this reason, this paper will not go into the factual determination of whether Mr. Sheen’s contract specified a particular term of employment or was vague as sadly, there is no complete copy of the entire contract. Thus, this section will hinge on the definition of “just cause,” and whether Warner Brothers and Mr. Lorre et. al. were justified in terminating Mr. Sheen’s contract based on this principle.

            The meaning of “just cause” can be defined by the parties to the contract. If unclear, Courts sometimes to look extrinsic evidence to assist in interpreting the provision.[41]  However, the default, when unclear or undefined, is the term’s “ordinary meaning.”[42] The broad definition of just cause may allow an employer to fire an employee for not only misconduct or poor performance, but also for legitimate economic reasons.[43] Just cause, thus, is a balance between an employer’s interest in operating its business and the employee’s interest in continued employment.[44] Thus, given those interests, it is not uncommon for employee’s to dispute the employer’s reasoning behind a just cause firing in court. In such circumstances, the burden of proof is on the employer, though courts are not yet in agreement as to what exactly the employer must show to satisfy its burden of proof.

            In this particular case, the operative section of Mr. Sheen’s contract is Section 19. Section 19 states:

“If Producer in its reasonable but good faith opinion believes Performer has committed an act which constitutes a felony offense involving moral turpitude under federal, state or local laws, or is indicted or convicted of any such offense, Producer shall have the right to delete the billing provided for in this agreement from any broadcast or other uses which are thereafter made in the episode(s) in which Performer appears. In addition, to the extent such event interferes with Performer’s ability to fully and completely render all material services required hereunder or Producer’s ability to fully exploit the Series, Producer shall have the right to treat such act under the applicable provisions hereof.”[45]

Counsel for Warner Brothers believes that there is “ample evidence supporting Warner Brothers’ reasonable good faith opinion that Mr. Sheen has committed felony offenses involving moral turpitude…”[46] Specifically, Warner Brothers alleges that Mr. Sheen “furnished… cocaine to others as part of the self-destructive lifestyle he has described publicly.”[47]

“Moral turpitude” is defined as the “readiness to do evil,” and often revolves around the intention of the perpetrator when committing the offense.[48] Solo drug use is not considered moral turpitude.[49] Domestic violence, however, can be a crime of moral turpitude.[50] This depends on the circumstances of the incident, and generally such things are factual issues that must be determined by a court.[51] The letter to Mr. Sheen on March 7 references at least one domestic violence incident involving Mr. Sheen. One incident in particular occurred on Christmas Day in 2009. Mr. Sheen allegedly held a knife to his then-wife, Brook Meuller, choking her and threatening to kill her after Ms. Meuller wanted a divorce.[52] Moreover, Mr. Sheen alleged that they had both “slapped each other’s arms” prior to his choking her.[53]

Under these circumstances, it can reasonably be argued that Mr. Sheen had the intent to willfully violate the “special relationship for which society rationally demands,” and set out to intentionally injure his wife. Thus, there may be a reasonably argue where it can be proven that Mr. Sheen displayed that “general readiness to do evil.” This would bring his actions to the level of crimes involving moral turpitude. Moreover, it is important to note that the first line of Section 19 of Mr. Sheen’s contract states that the Producer need only have a “reasonable but good faith opinion” that such an act occurred.[54] Given the circumstances of the December 25, 2009 Domestic Violence incident, it can be argued that the Producer did in fact have a reasonably and good faith opinion that Mr. Sheen had committed such an act.

Looking at the circumstances as a whole, and as set out by Warner Brothers’ reply letter to Mr. Sheen’s February 28, 2011 letter, there is nothing to indicate there was bad faith on the part of Warner Brothers or Mr. Lorre. To the contrary, there appears to be ample evidence to show that Warner Brothers and Mr. Lorre attempted to assist Mr. Sheen in ensuring that he does not continually fall into a downward spiral of drug abuse and embarrassing press releases. Apart from the personal visits and pleas for checking in to a rehabilitation center, the March 7, 2011 Letter states that Warner Brothers had an aircraft ready to take Mr. Sheen to a rehabilitation center, placing the show on hiatus to “provide Mr. Sheen with an opportunity to receive professional treatment.”[55] This, coupled with other incidents of Warner Brothers and Mr. Lorre attempting to assist Mr. Sheen and ensure his good health and the continuing production of Three and a Half Men can be used as evidence to counter any argument that they acted in bad faith.

However, this may not be the strongest argument that Warner Brothers and Mr. Lorre can make. If anything, this course of action is highly circumstantial, and moral turpitude, as previously shown, is highly fact sensitive, and may or may not work against Warner Brothers and Mr. Lorre. Mr. Sheen, in his defense, can raise issues of retaliatory firings or ulterior motives in showing that Warner Brothers and Mr. Lorre “had it out for him.” This, however, may not be successful as it is unlikely, given the evidence, the court will believe Mr. Sheen. Nevertheless, there are other provisions that can “make or break” the case. This paper will refer to them in the upcoming sections.


            Arbitration in Employment Litigation can be very one-sided, and some parties may or may not desire to engage in that form of alternative dispute resolution. Nevertheless, arbitration clauses are found in many employment contracts. Arbitration in the United States is governed by the Federal Arbitration Act, or the FAA, which was passed in 1925 and governs all arbitration clauses.[56] The law partially preempts state law in the sense that laws that invalidate arbitration on grounds other than fraud, unconsionability and duress will likely not be applicable. However, states are free to regulate the procedures used in arbitration.

            Specifically, Warner Brothers and Mr. Lorre have notified Mr. Sheen that they have “submitted [the] dispute to arbitration before [the Judicial Arbitration and Mediation Services], as required by the Agreement.”[57] Nevertheless, despite the notice, Mr. Sheen filed suit on March 10, 2011.  However, a “plaintiff who sues despite an arbitration agreement with the defendant is in breach of that agreement.”[58] The only way for a plaintiff to litigate is to “show that ground ‘for the revocation of any contract’ applies to the arbitration agreement,” which in other words brings the clause into the realm of “contract-law defenses” such as “misrepresentation, duress, or unconsionability.”[59] This makes it very difficult to get out of an arbitration agreement, in the case of Mr. Sheen, it would likely not be possible. Mr. Sheen’s bargaining power is not typical – he is no “unknown” in Hollywood. Warner Brothers and Mr. Lorre et. al. are profiting off of his acting, and such talent was not unknown prior to Three and a Half Men. It would seem that duress would likely be out of the question. The other two grounds, such as unconsionability and misrepresentation, will likely be difficult to prove as well. There is nothing in the facts presented by both parties through their letters and respective briefs that indicates such grounds have been pleaded in relation to the arbitration agreement.

Nevertheless, this warrants a brief discussion on the benefits and disadvantages of arbitrating the dispute from the perspective of both the employer and the employee. For the employer, arbitration typically results in lower rewards, saving them considerable sums of money as compared to litigation.[60] This translates to lower settlements and “fewer cases being brought in the first place.”[61] Secondly, arbitration is much cheaper than litigation, and thus the overall “cost of getting … the award is lower in arbitration.”[62] The advantages to the employer are apparent, and lower awards make it less likely for an employee with a legitimate claim to move forward.  However, there are instances where the arbitration can benefit the employee “only if it is truly voluntary and optional.”[63]

For example, arbitration can “serve as a beneficial alternative to litigation, especially for employees with small claims that do not justify litigation.”[64] Given that it is faster and less expensive, arbitration may actually give a lawyer incentive to take on cases that they otherwise would not have due to the costs of litigation.[65] With relaxed evidence rules and procedural mandates, arbitration can offer a less formal and confrontation atmosphere where disputes can truly be resolved. However, it is not common for employers to have voluntary arbitration clauses, and thus, the disadvantages noted above are more prominent. In that regard, it is now clear why Mr. Sheen’s counsel elected to bring suit regardless of the arbitration clause. It is likely, however, that the court will enforce the arbitration clause of the contract and send the matters to JAMS for arbitration.

Other Arguments

            While it seems that the Just Cause and Arbitration arguments are likely in Warner Brothers’ and Mr. Lorre’s favor, there are at least two other equally strong, if not stronger, arguments that can be made against Mr. Sheen. Section 14 of Mr. Sheen’s contract with Warner Brothers and Mr. Lorre et. al. is the Force Majeure clause, which typically allows parties to terminate the agreement when circumstances arise that are outside of their control. Section 14 defines Force Majeure as events by which the:

“…Producer is prevented from or hampered or interrupted or interfered with in preparing or producing the Series or any Program thereof or in utilizing Performer’s services hereunder… by reason of any other cause or causes of any similar nature or beyond our control, or by reason of the death, illness, disfigurement, Default or Incapacity of a member of the continuing principal cast of the series … or any other essential personnel associated with the series which (in the exercise of Producer’s sole but reasonable good faith discretion) (all of the forgoing are referred to as an event of Force Majeure) substantially prevents, hampers, interrupts or otherwise interferes with preparing or producing the Series.”[66]

The March 7 Letter states that Mr. Sheen’s “condition, conduct, admissions and statements described [and restated here in this paper] are clearly beyond the control of Warner Bothers and have substantially hampered, interrupted and interfered with [Warner Brothers’] production of the Series.”[67] The letter notes attempts by Warner Brothers to “persuade Mr. Sheen to seek help for his illness” that were rejected, and that as a result, the Producer is well within its discretion to terminate the contract. This can likely be proven by presenting outtakes showing Mr. Sheen “missing his marks,” “instances when [Mr. Sheen] showed up late to work,” or referencing attempts to get Mr. Sheen into rehabilitation that failed.[68] However, experts note that while this argument might be convincing, Mr. Sheen can rebut by presenting evidence showing that Warner Brothers and Mr. Lorre et. al. entered into the agreement well aware of Mr. Sheen’s pre-existing problems.[69]

Secondly, Section 13(a) of Mr. Sheen’s contract states, per pertinent part, that:

“Any publicity, paid advertisements, press notices and other information with respect to the … Series shall be under Producer’s sole control (excluding normal, incidental, non-derogatory publicity relating solely to Performer’s involvement with the… Series…). Therefore Performer shall not issue nor consent to, nor authorize any person or entity to release any such information without Producer’s express prior written approval.”[70]

The March 7, 2011 letter references the various derogatory comments that Mr. Sheen made in relation to the Series. The March 7, 2011 does not indicate, and Mr. Sheen does not claim, that any “prior written approval” was given prior to Mr. Sheen’s derogatory comments against Mr. Lorre concerning the Series and its production. This can be important in determining the extent of Mr. Sheen’s breach.[71] Given the early stages of the dispute, however, it will be difficult to tell. Nevertheless, this is a viable claim and will likely be pursued in court. Mr. Sheen may likely claim that he was not referring to the series, but merely making “normal, incidental” remarks relating to the show. However, some of the remarks were clearly derogatory in nature, and it is unclear how that will effect Mr. Sheen’s defense. Nevertheless, it is likely that Mr. Sheen will attempt to bring his comments within the normal, incident, and non-derogatory clause of Section 13(a) of his contract. This will likely be unsuccessful, however.


            It is the opinion of the author that the facts, as presented and with the assumptions made, favor Warner Brothers and Mr. Lorre et. al. Mr. Sheen’s actions were clearly in breach of the contract entered into by the parties, and it is likely that Mr. Sheen will not be victorious in either court or arbitration.

[1] While the contract in its entirety has been difficult to find, I have tried my best to verify the sources. The pertinent clauses of the contract are, however, available and will be analyzed. – Eds.
[2] Glynn, Anrow-Richman & Sullivan, Employment Law – Private Ordering and Its Limitations (2007)
[3] CBS – Two and a Half Men, <available at:> (Last viewed May 7, 2011)
[4] Id.
[5] Reuters, Update-1: Charlie Sheen Fired from Two and a Half Men, <available at:> (Last viewed May 7, 2011).
[6] Id.
[7] Letter dated February 28, 2011 written by Counsel for Charlie Sheen, Page 1.
[8] Id. at 2.
[9] Id.
[10] Id. at 3.
[11] Id.
[12] Id. at 4.
[13] Id. at 5.
[14] Letter Dated March 7, 2011 from Counsel from Warner Brothers to Charlie Sheen, Page 1.
[15] Id.
[16] Id.
[17] Id. at 2.
[18] The incident was an alleged domestic violence dispute that occurred early Christmas Day. An ambulance and police vehicle were called to an alleged dispute between Mr. Sheen and his wife in Colorado. Mr. Sheen’s wife allegedly called police after being pushed by Mr. Sheen. (See (Last viewed May 7, 2011).
[19] On October 27, 2010, Mr. Sheen was “found naked in a trashed Plaza Hotel room suite” after hotel security called 911. A woman told police that Mr. Sheen had begun “throwing furniture and yelling in his hotel room.” Officers observed a damaged room upon their arrival. (See (Last viewed May 7, 2011). On November 22, 2010, a news report came out alleging that Capri Anderson, alleged to be a “Porn Star,” was filing charges against Mr. Sheen after locking herself in the bathroom of Mr. Sheen’s trashed room during his rampage. (See (Last viewed May 7, 2011).
[20] March 7 Letter at 2.
[21] Id. at 3.
[22] Id.
[23] Id.
[24] Id. at 4.
[25] Id. Mr. Sheen also said that he “was banging seven gram rocks [of cocaine] and finishing them. That’s the way I roll.”
[26] Id.
[27] Id.
[28] March 7, 2011 Letter at 4.
[29] Id. at 5.
[30] Id.
[31] For example, Mr. Sheen stated, among other things, that “I have closed my eyes and in a nano second, I cured myself from their ridiculous model of a disease…” with reference to his drug addition.
[32] Id.
[33] Id.
[34] Id. The author believes the ‘octagon’ to mean a reference to Mixed Martial Arts, or MMA, where competitors quite literally beat one another to a pulp without any protective gear.
[35] Id. at 6.
[36] Case No. SC111794.
[37] Greene v. Oliver Reality Co., Pennsylvania 1987.
[38] Id. (“The at-will presumptions can be rebutted by clear evidence that the parties intended a contrary result.”)
[39] Cave Hill Corporation v. Heirs, Virginia 2002 (“Where employment is for a definite period, the presumption of at-will employment is rebutted and an employee may only be fired for just cause.”)
[40] Id.
[41] Uintah Basin Medical Center v. Hardy, Utah Ct. App. (2005) (“To interpret the just cause provision, the trial court relied primarily on extrinsic evidence…” including the actual understanding of the individual parties.)
[42] Id.
[43] Id.
[44] Id.
[45] March 7, 2011 Letter at 10.
[46] Id.
[47] Id.
[48] Donley v. Davy, 180 Cal. App. 4th 447, 458 (2009).
[49] People v. Vera, 69 Cal. App. 4th 1100, 1102-1103 (1999).
[50] Davy, 180 Cal. App 4th 447 at 457 (“An act of domestic violence does not inherently involve moral turpitude, as it can occur ‘without a readiness to do evil,’ and can occur when tempers flare out of control… the assailant must, at the very least, have set out, successfully, to injure a person of the opposite sex in a special relationship for which society rationally demands, and the victim may reasonably expect, stability and safety, and in which the victim, for these reasons among others, may be especially vulnerable. To have joined in, and thus necessarily to be aware of, that special relationship, and then to violate it wil[l]fully and with intent to injure, necessarily connotes the general readiness to do evil that has been held to define moral turpitude.”)
[51] Id.
[52] Fox News, Charlie Sheen Pleads Not Guilty to Domestic Violence Charges, <Available at:> (Last viewed May 7, 2011).
[53] Id.
[54] March 7, 2011 Letter at 9. (Emphasis added).
[55] Id. at 4.
[56] 9 U.S.C. § 1 et. seq. (This is not to be confused with the Federal Aviation Administration, which also uses the ‘FAA’ abbreviation.)
[57] March 7, 2011 Letter at 10.
[58] Stephen J. Ware, The Effects of Gilmer: Empirical and Other Approaches to the Study of Employment Arbitration, 16 Ohio St. J. on Disp. Resol. 735, 738 (2001).
[59] Id.
[60] Id. at 747.
[61] Id.
[62] Id.
[63] Employee Rights and Employment Policy Journal, Focus on Arbitration After Gilmer: Neri’s Position on Mandatory Arbitration of Employment Disputes, 1 Employee Rts. & Emp. Pol’y J. 263 (1997).
[64] Id.
[65] Id.
[66] March 7, 2011 Letter at 8.
[67] Id. at 9.
[68] The Hollywood Reporter, Charlie Sheen’s Contract: Was There Actually A Moral’s Clause? (Analysis), <Available at:> (Last Viewed May 7, 2011).
[69] Id.
[70] March 7, 2011 Letter at 9.
[71] The Hollywood Reporter.

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