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of those horses that petitioner showed won New England Champion.
In the early 1960's, both petitioners worked for the California
Breeders Association in Circleville, Utah. Petitioners were in
charge of breeding 12 stallions to over 100 mares on this farm.
After leaving the California Breeders Association, petitioners
moved to California and worked for Mr. John Dick, where they
managed and trained horses on his farm. Then in the mid-1960's,
petitioners took jobs not associated with the horse business.
In 1982 petitioners bought their house in Whittier on a
half-acre parcel zoned “R-1”, which does not permit horses.
However, many of petitioners’ neighbors also kept horses. In
1984, petitioners erected a portable barn on their property. The
barn had a breezeway and four stalls. In back of the barn were
four pipe pens. Petitioners acquired quarter horses around this
time with the intent to breed and race them. In 1985 petitioners
filed a Fictitious Business Name Statement stating that they were
doing business as Midget Acres. Petitioners also received a
public health license issued by the County of Los Angeles. Los
Angeles County Code section 7.04.010 requires a license before
the commencement of any business activity. Petitioners did not
have a business license.
In 1986 and 1987 petitioners worked at the Kerr stock farm
(the Kerr farm) where petitioner trained horses.3 Petitioners
took their own horses with them to the Kerr farm, where they
3 Petitioner testified that Mr. Pitts worked on underwater
treadmills for the horses at the Kerr farm.
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