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In page Fog Over Frisco:

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Bette Davis, anxious to portray the slatternly waitress Mildred in the RKO Radio Pictures production Of Human Bondage, accepted the relatively small role of Arlene in the hope her cooperation would convince Jack L. Warner to lend her to the rival studio for the film. Her ploy worked, and when Warner received word about her dynamic performance in Bondage, he elevated her to top billing in Frisco.[1]