Ronald H. Bradshaw and Monica I. Bradshaw - Page 18

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                  Contrary to these assertions, there is no evidence in               
             the record to suggest that Motion, Inc.'s line of credit                 
             and security agreement had anything to do with petitioner                
             in his individual capacity, as opposed to his capacity as                
             corporate officer of Motion, Inc.  There is also no                      
             evidence to suggest that Motion, Inc., was not a validly                 
             existing corporation and thus a separate entity from                     
             petitioner.  In fact, petitioner's opening brief refers to               
             Motion, Inc., as "a wholly owned corporation of Petitioner,              
             Ronald Bradshaw", and petitioners' reply brief refers to it              
             as "Petitioner's wholly owned corporation, Motion, Inc."                 
                  Colonial Bank's original petition, by which it                      
             initiated suit against petitioner and Motion, Inc., does                 
             not suggest that the proceeds of petitioner's check-kiting               
             scheme had been obtained through a bona fide indebtedness.               
             To the contrary, the principal claim in the original                     
             complaint was a "CLAIM FOR REIMBURSEMENT" under which                    
             Colonial Bank sought to hold petitioner and Motion, Inc.,                
             liable based upon the fact that petitioner had deposited                 
             into his account at Colonial Bank worthless checks drawn on              
             the account of Motion, Inc., in Tarrant Bank, and the fact               
             that Colonial Bank was a holder in due course with respect               
             to each of those checks.  The original petition also sought              
             to foreclose its security interest in assets owned by or                 
             due to Motion, Inc., and to obtain any proceeds that had                 




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