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On December 10, 1984, and January 7, 1985, petitioner filed
a Complaint for Damages and an Amendment to Complaint,
respectively, in the Superior Court entitled Raymond A.
Moorefield v. Charles W. Wright, et al. (Moorefield v. Wright--
suit No. 2). On or about December 4, 1985, petitioner filed
another complaint against Wright in the Superior Court entitled
Raymond A. Moorefield v. Charles W. Wright, et al. (Moorefield v.
Wright--suit No. 3). The causes of action in Moorefield v.
Wright--suit No. 3 included anticipatory breach of contracts and
agreements, breach of trust, breach of trust with fraudulent
intentions, interference with contracts and agreements,
conspiracy, quiet title, specific performance, and declaratory
relief.
On January 8, 1988, a Settlement Agreement and General
Release was filed in Moorefield v. Wright--suit No. 3 (the
settlement agreement). The settlement agreement provided for
disposition of the three previously filed lawsuits in which
petitioner was a plaintiff against Wright and a release of all
claims. The settlement agreement further provided that Wright
would pay to petitioner the sum of $1,100,000.
On April 8, 1988, Wright paid petitioner the sum of
$1,055,000. Approximately $750,000 of this amount was paid to
petitioner’s children pursuant to assignments executed by
petitioner in 1985. The additional amount of $45,000 was sent to
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