The following excerpt is from City of Santa Cruz v. Wykes, 202 F. 357 (9th Cir. 1913):
'An obligation will be enforced, though indirectly connected with an illegal transaction, if it is supported by an independent consideration, so that the plaintiff does not require the aid of the illegal transaction to make out his case. ' Armstrong v. American Exchange Bank, 133 U.S. 433, 469, 10 Sup.Ct. 450, 461 (33 L.Ed. 747).
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