Dennis A. and Tai K. Praegitzer - Page 8

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          and Mr. Murphy and Ms. Dragland represented petitioner                      
          Praegitzer.  After discussions between Mr. Lopez, Mr. Murphy, and           
          Justice Janes, a memorandum of agreement (the 12/12 agreement)              
          was typed at the urging of Justice Janes and was signed by Mr.              
          Lopez and Mr. Murphy.  The 12/12 agreement was not signed by                
          petitioner Dawes or by petitioner Praegitzer.  Justice Janes                
          signed the 12/12 agreement approving it “as a judicial                      
          settlement.”  Justice Janes stated to the attorneys that if they            
          encountered any problems, they were to come back to see him to              
          resolve the matter.                                                         
               The memorandum of agreement, dated December 12, 1989,                  
          provided as follows:                                                        
               This appeal is settled this date upon the following                    
               conditions:                                                            
               1.  The Respondent [petitioner Dawes] will pay in cash                 
               $103,000 to Appellant [petitioner Praegitzer].                         
               2.  The Corporation will transfer rights to products                   
               known as “303" and “306" including inventory and                       
               equipment, the equipment determined as a forklift and a                
               binding machine, to the extent inventory is less than                  
               $59,000, it will be made up by Respondent.                             
               3.  No royalties on products sold by Appellant after                   
               this date (ok Lopez; ? George).                                        
               4.  A three and a half year covenant not to compete in                 
               the propellor shop business in Washington, Oregon,                     
               California and Nevada.                                                 
               5.  Kathy Dawes to forgive judgments and cancelled                     
               notes in the amount of $36,097.65 (method of                           
               forgiveness to be determined jointly by counsels' tax                  
               counsel.)                                                              
               6.  Corporation to forgive debt owed by Appellant in                   
               the amount of $21,000.                                                 



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