California, United States of America
The following excerpt is from Chambers v. Kay, 126 Cal.Rptr.2d 536, 29 Cal.4th 142, 56 P.3d 645 (Cal. 2002):
Our decision to affirm the importance of written consent is consistent with Scolinos v. Kolts (1995) 37 Cal.App.4th 635, 44 Cal. Rptr.2d 31 (Scolinos) and Margolin, supra, 85 Cal.App.4th 891, 102 Cal.Rptr.2d 502, which denied recovery for breaches of referral fee agreements where there was no compliance with the disclosure and consent requirements of rule 2-200 and its predecessor, former rule 2-108.
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