This section is from the book "American Law Of Real Estate Agency", by William Slee Walker. Also available from Amazon: American law of real estate agency.
While Civil Code, Sec. 1624, requiring agreements employing brokers to buy or sell real estate for hire to be in writing, does not extend to agreements between brokers to co-operate in making sales for a share of the commission, and recovery may be had in such cases on proof of an oral agreement; this pre-supposes that a valid contract for commissions is extant, a division of which could be subject of subsequent oral agreement. Saunders v. Yoakum, 107 P. 1007, 12 Cal. App. 543; Hageman v. O'Brien, 141 P. 33, 24 Cal. App. 270; Hiedak v. Allen, 147 P. 474, 26 Cal. App. 509; Mackroth v. Sinky, 148 P. 978, 27 Cal. App. 112; Giles v. Wilmott, 52 S. 287, 59 Fla. 271; Egeland v. Schiller, 189 I11. App. 426; Blake v. Hunkey, 128 P. 181, 88 Kan. 272; Collins v. Belford & Stump, 130 P. 662, 89 Kan. 92; White v. Robinson, 138 N. Y. Sup. 992, 153 App. Div. 776.
 
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