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in Florida throughout October, November, and December 1996. From
May 15 through September 30, 1996, petitioner had a personal
savings account with First Union Bank. The savings account
statements showed petitioner’s address in Hallandale. Petitioner
conducted banking transactions in his savings account in both
Florida and California throughout the months covered by the
statements, with the last transaction in Florida occurring on
August 5, 1996. At the time of trial, petitioner continued to
use a Florida address on his checks.
Employment with Warner Bros. Television Productions
In 1995 and early 1996, petitioner was employed by Warner
Bros. Television Productions (Warner Bros.) filming a pilot
television program in Seattle, Washington. A Warner Bros.
employee suggested to petitioner that he move from Florida to
California to facilitate his hiring by Warner Bros. in California
because production companies are required to pay higher “distant
location” rates for an out-of-State director under the Director’s
Guild of America contract. On July 10, 1996, petitioner executed
documents with Warner Bros. concerning his work for the
television program “The Drew Carey Show”. A “Film DGA Deal Memo”
(deal memo) listed petitioner’s weekly salary with a guaranty of
work for 1 week as a unit production manager. Petitioner also
did business with Warner Bros. under the name Jigsaw Productions,
Inc. (Jigsaw). Petitioner’s and Jigsaw’s address as listed in
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