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|alma_mater = [[Harvard University]] (B.A., 1974); [[Oxford University]] (Balliol College, B. Phil. 1976); [[University of California, Berkeley]] (J.D. 1979)
|alma_mater = [[Harvard University]] (B.A., 1974); [[Oxford University]] (Balliol College, B. Phil. 1976); [[University of California, Berkeley]] (J.D. 1979)
|other_names =
|other_names =
|known_for = Director of California's [[Employment Development Department]], 1999-2004<br>Author of a series of writings on employment and job training written from the practitioner experience<br>Director of the BART transit system
|known_for = Director of California's [[Employment Development Department]]<br>Author of a series of books and articles on employment and job training written from the practitioner experience<br>Director of the BART transit system, early transit village proponent
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'''Michael S. Bernick''' (born October 1, 1952) is an [[Americans|American]] [[lawyer]]. He served as Director of California's labor department, the [[Employment Development Department]] (EDD) from 1999 to 2004. He is a practitioner and theorist of job training and employment strategies. In a series of articles and books written during the 1980s and 1990s, drawing on his experience in community job training, he argues against the then-expanding [[social welfare system]]. He sets out alternative strategies of [[inner city]] [[entrepreneurship]] and [[Market (economics)|market]]-based training and job ladders. In the 2000s, his practice and writing turned to worker retraining and reemployment strategies, including a series of local job training projects targeting displaced workers in California. Today, he is also active in developing local training projects for workers with autism and other neurodiverse conditions.
'''Michael S. Bernick''' (born October 1, 1952) is an [[Americans|American]] [[lawyer]]. He served as Director of California's labor department, the [[Employment Development Department]] (EDD) from 1999 to 2004. He is a practitioner and theorist of job training and employment strategies. For over 40 years, he has developed job training projects on the state and local level in California and written about strategies for expanding the middle class and achieving fuller employment.

In a series of articles and books written during the 1980s and 1990s, drawing on his experience in community job training, he argues against the then-expanding [[social welfare system]]. He sets out alternative strategies of [[inner city]] [[entrepreneurship]] and [[Market (economics)|market]]-based training and job ladders.

In the 2000s, his projects first at the EDD and then through the California Workplace Association (CWA) include ones of worker retraining and reemployment, improving the income of low-wage workers, and employment for workers who have been unable to find steady work. He has written regularly on these topics, including a volume on the lessons of training programs for the past fifty years, and two volumes on expanding jobs for workers with developmental and neurological differences.


==Early life and education==
==Early life and education==
Bernick grew up in [[Los Angeles]] through [[Fairfax High School (Los Angeles, California)|Fairfax High School]]. A marathon runner in the 1960s, he was active in the long distance running subculture of Southern California.<ref>{{cite web|url=http://www.zocalopublicsquare.org/2011/06/21/when-running-became-life/chronicles/who-we-were/|title=Zócalo Public Square :: When Running Became Life|work=Zocalo Public Square +|accessdate=21 June 2011}}</ref> He attended [[Harvard University]] (B.A. 1974), Oxford University ([[Balliol College, Oxford|Balliol College]], [[Bachelor of Philosophy|B. Phil.]] 1976) and the [[UC Berkeley School of Law|University of California, Berkeley Law School]] (J.D. 1979).
Bernick grew up in [[Los Angeles]] through [[Fairfax High School (Los Angeles, California)|Fairfax High School]]. A marathon runner in the 1960s, he was active in the long distance running subculture of Southern California at that time.<ref>{{cite web|url=http://www.zocalopublicsquare.org/2011/06/21/when-running-became-life/chronicles/who-we-were/|title=Zócalo Public Square :: When Running Became Life|work=Zocalo Public Square +|accessdate=21 June 2011}}</ref> He attended [[Harvard University]] (B.A. 1974), Oxford University ([[Balliol College, Oxford|Balliol College]], [[Bachelor of Philosophy|B. Phil.]] 1976) and the [[UC Berkeley School of Law|University of California, Berkeley Law School]] (J.D. 1979). He spent his final year of law school om Washington DC researching a monograph on judge J. Skelly Wright.<ref>{{cite web|url=https://repository.uchastings.edu/cgi/viewcontent.cgi?article=1199&context=hastings_constitutional_law_quaterly|title=The Unusual Odyssey of J. Skelly Wright|work=Hastings Constitutional Law Quarterly +|accessdate=Summer 1980}}</ref>


==Career==
==Career in the Employment Field==
After graduating from law school, he spent much of the next seven years as executive director of the San Francisco Renaissance Center, a community job training agency that operated a series of literacy and vocational training classes, an early welfare to work program, and five business ventures providing transitional employment. In 1986 Bernick went into private law practice but remained a board member of several community job training agencies until being appointed EDD Director in 1999.
After graduating from law school in 1979, he spent much of the next seven years as executive director of the San Francisco Renaissance Center, a community job training agency that operated a series of literacy and vocational training classes, an early welfare to work program, and five business ventures providing transitional employment. In 1986 Bernick went into private law practice with the law firm of Arnelle and Hastie but remained a board member of several community job training agencies until being appointed EDD Director in 1999.


Following the recall of California Governor [[Gray Davis]], Bernick returned to law in San Francisco, at Sedgwick LLP (2004-2017) and later at Duane Morris LLP (2018-present). He also joined the Milken Institute as a fellow in employment policy. He continues to be active with several community job training agencies and work force intermediaries in California and with the Autism Job Club.
Following the recall of California Governor [[Gray Davis]], Bernick returned to law in San Francisco, at Sedgwick LLP (2004-2017) and later at Duane Morris LLP (2018-present). He also joined the Milken Institute in 2004 as a fellow in employment policy and became research director of CWA, positions that continue today. In 2011, he helped create and continues to direct the Autism Job Club of the Bay Area.


===Criticism of the Welfare State, and Developing Market-Oriented Job Creation and Training===
===1980s and 1990s: Criticism of the Welfare State, and Developing Market-Oriented Job Creation and Training===
In the early 1980s, Bernick began a series of articles and books on job training and employment, written from the viewpoint of the practitioner. ''The Dreams of Jobs'' (1982) reviews the job training programs in San Francisco from 1960 to 1980, and was followed a few years later by ''Urban Illusions'' (1986), covering job training experiences at the Renaissance Center.<ref>''The Dreams of Jobs'' (Olympus, 1982) {{ISBN|978-0-913420-48-5}}; '' Urban Illusions'' (Praeger, 1986) {{ISBN|978-0-275-92804-9}}</ref>
In the early 1980s, Bernick began a series of articles and books on job training and employment, written from the viewpoint of the practitioner. ''The Dreams of Jobs'' (1982) reviews the job training programs in San Francisco from 1960 to 1980, and was followed a few years later by ''Urban Illusions'' (1986), covering job training experiences at the Renaissance Center.<ref>''The Dreams of Jobs'' (Olympus, 1982) {{ISBN|978-0-913420-48-5}}; '' Urban Illusions'' (Praeger, 1986) {{ISBN|978-0-275-92804-9}}</ref>


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After becoming EDD Director in 1999, Bernick continued to write about training strategies, particularly job ladders for low wage workers<ref>"To Rise Above, Upgrading the Skills of the Under-Employed", ''Milken Institute Review'', 2001</ref> and employment for workers with disabilities.<ref>"Making Work Pay—For the Disabled Too", ''Milken Institute Review'', Fourth Quarter 2003</ref> His 2006 book, ''Job Training That Gets Results'' is an attempt to summarize lessons learned from the job training programs of the past 50 years. It contains the themes of market-oriented training and entrepreneurship, along with the professionalization of the low wage workforces, role of extra-governmental entities, and restructuring of government social services structures.<ref>''Job Training That Gets Results: 10 Principles of Effective Employment Programs'' (Upjohn Institute, 2006) {{ISBN|978-0-88099-280-0}}</ref>
After becoming EDD Director in 1999, Bernick continued to write about training strategies, particularly job ladders for low wage workers<ref>"To Rise Above, Upgrading the Skills of the Under-Employed", ''Milken Institute Review'', 2001</ref> and employment for workers with disabilities.<ref>"Making Work Pay—For the Disabled Too", ''Milken Institute Review'', Fourth Quarter 2003</ref> His 2006 book, ''Job Training That Gets Results'' is an attempt to summarize lessons learned from the job training programs of the past 50 years. It contains the themes of market-oriented training and entrepreneurship, along with the professionalization of the low wage workforces, role of extra-governmental entities, and restructuring of government social services structures.<ref>''Job Training That Gets Results: 10 Principles of Effective Employment Programs'' (Upjohn Institute, 2006) {{ISBN|978-0-88099-280-0}}</ref>


===Worker Employment Strategies During the Great Recession and in the Years After===
===2000s: Expanding the Middle Class and Fuller Employment===
After leaving EDD in 2004, Bernick's practice and writing turned to worker retraining and reemployment strategies. In twice-monthly California employment postings dating from early 2009 for the website ''Fox & Hounds'', he chronicled the large scale job losses in California employment during the [[Great Recession]]<ref>{{cite web|url=http://www.foxandhoundsdaily.com/author/MichaelBernick/|title=Michael Bernick - Fox&Hounds|work=Fox&Hounds|accessdate=28 July 2015}}</ref> and the transformation of California industries. In essays for ''Zocalo Public Square'' and other journals, he examined a range of employment issues: the breakdown in full-time employment and rise of alternative forms of employment,<ref>http://www.zocalopublicsquare.org/2012/04/29/were-all-temps-now/chronicles/who-we-were/; and "Huge Job Creation, Destruction Requires Adaptation by Employment Lawyers," Daily Journal, August 11, 2006, "The Future of Bay Area Employment", San Francisco Chronicle Sunday Insight, Sept. 27, 2009</ref> the projected growth of the "non-knowledge economy,"<ref>{{cite web|url=http://www.sfgate.com/opinion/article/Reality-TV-workers-show-way-to-better-economy-2461654.php|title=Reality-TV workers show way to better economy|work=[[San Francisco Chronicle]]|accessdate=28 July 2015}}</ref> the evolving forms of job placement,<ref>{{cite web|url=http://www.zocalopublicsquare.org/2013/05/24/five-ways-to-get-a-job-in-california/ideas/nexus/|title=Zócalo Public Square :: Five Ways to Get a Job in California|work=Zocalo Public Square +|accessdate=28 July 2015}}</ref> policies that restrict job creation,<ref>{{cite web|url=http://www.zocalopublicsquare.org/2013/08/29/lets-stop-making-it-hard-to-create-jobs/ideas/nexus/|title=Zócalo Public Square :: Let's Stop Making It Hard to Create Jobs|work=Zocalo Public Square +|accessdate=28 July 2015}}</ref> crowdfunding and anti-poverty impacts,<ref>{{cite web|url=http://www.sfgate.com/opinion/openforum/article/San-Francisco-s-end-of-cool-Nonsense-4221916.php|title=San Francisco's end of cool? Nonsense|work=[[San Francisco Chronicle]]|accessdate=28 July 2015}}</ref> and why most approaches today to wage inequality are ineffective.<ref>{{cite web|url=http://www.zocalopublicsquare.org/2014/01/10/wanna-fix-californias-wage-inequality/ideas/nexus/|title=Zócalo Public Square :: Wanna Fix California's Wage Inequality?|work=Zocalo Public Square +|accessdate=28 July 2015}}</ref> Since 2016, Bernick has been a regular contributor to ''Forbes''<ref>{{Cite web|url=https://www.forbes.com/sites/michaelbernick/|title=List of articles published on Forbes by Michael Bernick|last=Bernick|first=Michael|website=Forbes|access-date=2017-05-05}}</ref> on employment issues.
After leaving EDD in 2004, Bernick's practice and writing turned to worker retraining and reemployment strategies. In twice-monthly California employment postings dating from early 2009 for the website ''Fox & Hounds'', he chronicled the large scale job losses in California employment during the [[Great Recession]]<ref>{{cite web|url=http://www.foxandhoundsdaily.com/author/MichaelBernick/|title=Michael Bernick - Fox&Hounds|work=Fox&Hounds|accessdate=28 July 2015}}</ref> and the transformation of California industries. In essays for ''Zocalo Public Square'' and other journals, he examined a range of employment issues: the breakdown in full-time employment and rise of alternative forms of employment,<ref>http://www.zocalopublicsquare.org/2012/04/29/were-all-temps-now/chronicles/who-we-were/; and "Huge Job Creation, Destruction Requires Adaptation by Employment Lawyers," Daily Journal, August 11, 2006, "The Future of Bay Area Employment", San Francisco Chronicle Sunday Insight, Sept. 27, 2009</ref> the projected growth of the "non-knowledge economy,"<ref>{{cite web|url=http://www.sfgate.com/opinion/article/Reality-TV-workers-show-way-to-better-economy-2461654.php|title=Reality-TV workers show way to better economy|work=[[San Francisco Chronicle]]|accessdate=28 July 2015}}</ref> the evolving forms of job placement,<ref>{{cite web|url=http://www.zocalopublicsquare.org/2013/05/24/five-ways-to-get-a-job-in-california/ideas/nexus/|title=Zócalo Public Square :: Five Ways to Get a Job in California|work=Zocalo Public Square +|accessdate=28 July 2015}}</ref> policies that restrict job creation,<ref>{{cite web|url=http://www.zocalopublicsquare.org/2013/08/29/lets-stop-making-it-hard-to-create-jobs/ideas/nexus/|title=Zócalo Public Square :: Let's Stop Making It Hard to Create Jobs|work=Zocalo Public Square +|accessdate=28 July 2015}}</ref> crowdfunding and anti-poverty impacts,<ref>{{cite web|url=http://www.sfgate.com/opinion/openforum/article/San-Francisco-s-end-of-cool-Nonsense-4221916.php|title=San Francisco's end of cool? Nonsense|work=[[San Francisco Chronicle]]|accessdate=28 July 2015}}</ref> and why most approaches today to wage inequality are ineffective.<ref>{{cite web|url=http://www.zocalopublicsquare.org/2014/01/10/wanna-fix-californias-wage-inequality/ideas/nexus/|title=Zócalo Public Square :: Wanna Fix California's Wage Inequality?|work=Zocalo Public Square +|accessdate=28 July 2015}}</ref> Since 2016, Bernick has been a regular contributor to ''Forbes''<ref>{{Cite web|url=https://www.forbes.com/sites/michaelbernick/|title=List of articles published on Forbes by Michael Bernick|last=Bernick|first=Michael|website=Forbes|access-date=2017-05-05}}</ref> on employment issues.



Revision as of 17:38, 28 May 2021

Michael S. Bernick
Michael Bernick in 2017
Born (1952-10-01) October 1, 1952 (age 71)
NationalityAmerican
Alma materHarvard University (B.A., 1974); Oxford University (Balliol College, B. Phil. 1976); University of California, Berkeley (J.D. 1979)
Known forDirector of California's Employment Development Department
Author of a series of books and articles on employment and job training written from the practitioner experience
Director of the BART transit system, early transit village proponent
WebsiteDuaneMorris

Michael S. Bernick (born October 1, 1952) is an American lawyer. He served as Director of California's labor department, the Employment Development Department (EDD) from 1999 to 2004. He is a practitioner and theorist of job training and employment strategies. For over 40 years, he has developed job training projects on the state and local level in California and written about strategies for expanding the middle class and achieving fuller employment.

In a series of articles and books written during the 1980s and 1990s, drawing on his experience in community job training, he argues against the then-expanding social welfare system. He sets out alternative strategies of inner city entrepreneurship and market-based training and job ladders.

In the 2000s, his projects first at the EDD and then through the California Workplace Association (CWA) include ones of worker retraining and reemployment, improving the income of low-wage workers, and employment for workers who have been unable to find steady work. He has written regularly on these topics, including a volume on the lessons of training programs for the past fifty years, and two volumes on expanding jobs for workers with developmental and neurological differences.

Early life and education

Bernick grew up in Los Angeles through Fairfax High School. A marathon runner in the 1960s, he was active in the long distance running subculture of Southern California at that time.[1] He attended Harvard University (B.A. 1974), Oxford University (Balliol College, B. Phil. 1976) and the University of California, Berkeley Law School (J.D. 1979). He spent his final year of law school om Washington DC researching a monograph on judge J. Skelly Wright.[2]

Career in the Employment Field

After graduating from law school in 1979, he spent much of the next seven years as executive director of the San Francisco Renaissance Center, a community job training agency that operated a series of literacy and vocational training classes, an early welfare to work program, and five business ventures providing transitional employment. In 1986 Bernick went into private law practice with the law firm of Arnelle and Hastie but remained a board member of several community job training agencies until being appointed EDD Director in 1999.

Following the recall of California Governor Gray Davis, Bernick returned to law in San Francisco, at Sedgwick LLP (2004-2017) and later at Duane Morris LLP (2018-present). He also joined the Milken Institute in 2004 as a fellow in employment policy and became research director of CWA, positions that continue today. In 2011, he helped create and continues to direct the Autism Job Club of the Bay Area.

1980s and 1990s: Criticism of the Welfare State, and Developing Market-Oriented Job Creation and Training

In the early 1980s, Bernick began a series of articles and books on job training and employment, written from the viewpoint of the practitioner. The Dreams of Jobs (1982) reviews the job training programs in San Francisco from 1960 to 1980, and was followed a few years later by Urban Illusions (1986), covering job training experiences at the Renaissance Center.[3]

Bernick was an early proponent of what became welfare reform under President Bill Clinton,[4] and of market-based approaches to vocational and literacy training.[5] He also argued for strategies of inner city entrepreneurship[6] and inner city loan funds.[7]

After becoming EDD Director in 1999, Bernick continued to write about training strategies, particularly job ladders for low wage workers[8] and employment for workers with disabilities.[9] His 2006 book, Job Training That Gets Results is an attempt to summarize lessons learned from the job training programs of the past 50 years. It contains the themes of market-oriented training and entrepreneurship, along with the professionalization of the low wage workforces, role of extra-governmental entities, and restructuring of government social services structures.[10]

2000s: Expanding the Middle Class and Fuller Employment

After leaving EDD in 2004, Bernick's practice and writing turned to worker retraining and reemployment strategies. In twice-monthly California employment postings dating from early 2009 for the website Fox & Hounds, he chronicled the large scale job losses in California employment during the Great Recession[11] and the transformation of California industries. In essays for Zocalo Public Square and other journals, he examined a range of employment issues: the breakdown in full-time employment and rise of alternative forms of employment,[12] the projected growth of the "non-knowledge economy,"[13] the evolving forms of job placement,[14] policies that restrict job creation,[15] crowdfunding and anti-poverty impacts,[16] and why most approaches today to wage inequality are ineffective.[17] Since 2016, Bernick has been a regular contributor to Forbes[18] on employment issues.

As a practitioner, Bernick has joined with workforce intermediaries and businesses in implementing worker retraining for growth occupations in engineering,[19] health care, and information technology.[20] With the California Workforce Association, he has been part of several pilot projects, utilizing the emerging internet job search and placement tools, expanding the apprenticeship approach to non-traditional fields, testing reemployment strategies for the long term unemployed, and testing public service employment for adults with developmental differences.

The Autism Job Club

Bernick has been involved since 2004 in a series of projects involving adults on the autistic spectrum. He was part of teams developing programs for persons with autism at California State University East Bay and at William Jessup University.[21] He helped develop The Specialists Guild, employing persons with autism in software testing, and the Autism Job Club, for building extra-governmental autism employment networks.[22] In March 2015, The Autism Job Club: The Neurodiverse Workforce in the New Normal of Employment, was published, setting out individual and collective strategies for increasing employment among adults on the autistic spectrum.[23] In the past few years, he has focused on forms of public service employment for adults on the autism spectrum, especially those who are more severely impacted.[24]

Transit Village Movement

In 1988 Bernick was elected to the board of directors of the Bay Area Rapid Transit (BART) rail system and soon began to note the lack of land development linked to rail. With UC Berkeley Professor Robert Cervero, he established a research center at UC Berkeley focused on the link of land use and transit, and together they published a series of articles leading to their 1996 book, Transit Villages in the 21st Century.[25] The book helped to develop and popularize the transit village concept.

Controversy

Veteran Bay Area investigative reporters Matier & Ross wrote in the San Francisco Chronicle in June 1996 that the newly elected BART Director Michael Bernick "accepted campaign contributions from BART contractors". And "excerpts of a federal wire tap [released in connection with indictments] showed that Bernick regularly talked to contractors about extending a deal for them at the same time they were helping to raise campaign contributions for his re-election." [26]

California State Library Collection of Writings

In October 2015, the California State Library opened a collection of Bernick's writings and papers.[27] The Collection includes over 200 articles by Bernick covering 35 years, as well as background material on his five books and two additional book projects-The Jobs Perplex and Real Work. The main section focuses on job training and employment strategies.[28] The collection also includes sections on the transit village movement in California, autism employment and inclusion, California government, and the long distance running sub-culture of Southern California.[29]

References

  1. ^ "Zócalo Public Square :: When Running Became Life". Zocalo Public Square +. Retrieved 21 June 2011.
  2. ^ "The Unusual Odyssey of J. Skelly Wright". Hastings Constitutional Law Quarterly +. Retrieved Summer 1980. {{cite web}}: Check date values in: |accessdate= (help)
  3. ^ The Dreams of Jobs (Olympus, 1982) ISBN 978-0-913420-48-5; Urban Illusions (Praeger, 1986) ISBN 978-0-275-92804-9
  4. ^ "How Welfare Can Work", Washington Monthly, Sept. 1985
  5. ^ "Illiteracy and Inner City Unemployment", Phi Delta Kappan, Jan 1986; "The Truth About Job Training Programs", Journal of Contemporary Studies, Winter 1984.
  6. ^ "Business in the Inner City", Harvard Business Review, November–December 1984
  7. ^ "The New Inner City Loan Funds", Planning, September 1986
  8. ^ "To Rise Above, Upgrading the Skills of the Under-Employed", Milken Institute Review, 2001
  9. ^ "Making Work Pay—For the Disabled Too", Milken Institute Review, Fourth Quarter 2003
  10. ^ Job Training That Gets Results: 10 Principles of Effective Employment Programs (Upjohn Institute, 2006) ISBN 978-0-88099-280-0
  11. ^ "Michael Bernick - Fox&Hounds". Fox&Hounds. Retrieved 28 July 2015.
  12. ^ http://www.zocalopublicsquare.org/2012/04/29/were-all-temps-now/chronicles/who-we-were/; and "Huge Job Creation, Destruction Requires Adaptation by Employment Lawyers," Daily Journal, August 11, 2006, "The Future of Bay Area Employment", San Francisco Chronicle Sunday Insight, Sept. 27, 2009
  13. ^ "Reality-TV workers show way to better economy". San Francisco Chronicle. Retrieved 28 July 2015.
  14. ^ "Zócalo Public Square :: Five Ways to Get a Job in California". Zocalo Public Square +. Retrieved 28 July 2015.
  15. ^ "Zócalo Public Square :: Let's Stop Making It Hard to Create Jobs". Zocalo Public Square +. Retrieved 28 July 2015.
  16. ^ "San Francisco's end of cool? Nonsense". San Francisco Chronicle. Retrieved 28 July 2015.
  17. ^ "Zócalo Public Square :: Wanna Fix California's Wage Inequality?". Zocalo Public Square +. Retrieved 28 July 2015.
  18. ^ Bernick, Michael. "List of articles published on Forbes by Michael Bernick". Forbes. Retrieved 2017-05-05.
  19. ^ "Growth Sector". growthsector.org. Retrieved 2017-05-05.
  20. ^ "Transmosis | An organization founded by Silicon Valley Technology Entrepreneurs dedicated to the research and application of technology to strengthen the American workforce". transmosis.com. Retrieved 2017-05-05.
  21. ^ San Francisco Chronicle; Aug. 4, 2009 (12 December 2012). "College for autistics". csueastbay.edu. Retrieved 28 July 2015.{{cite web}}: CS1 maint: multiple names: authors list (link) CS1 maint: numeric names: authors list (link)
  22. ^ "Zócalo Public Square :: The Autism Job Club". Zocalo Public Square +. Retrieved 28 July 2015.
  23. ^ The Autism Job Club: The Neurodiverse Workforce in the New Normal of Employment (Skyhorse, 2015) ISBN 978-1632206961
  24. ^ California State Library Multimedia (2017-03-06), Employment for California’s Adults with Autism in 2017, retrieved 2017-05-05
  25. ^ Transit Villages in the 21st Century (McGraw Hill, 1996) ISBN 978-0-07-005475-2.
  26. ^ "BART Director Reveals New Instance of Potential Conflict". SFGate. Retrieved 28 July 2015.
  27. ^ "Collection of Writings and Papers by Michael Bernick". California State Library.
  28. ^ Jason Bowman. "A Treasure Trove of California Job History" (PDF). California State Library Foundation Bulletin No. 120, 2018.
  29. ^ "Michael S. Bernick writings, 1970-2015". oac.cdlib.org. Retrieved 2020-09-28.