Geraldine H. Pearson - Page 6

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          Petitioner called Dixon a couple of times from Virginia to                  
          discuss the farm.  Petitioner called the people responsible for             
          her farm at least twice a week while she was in Virginia.                   
               Petitioner sold a horse named Fraulein Oneonta for $1,200              
          to an Oregon buyer in June 1988.  Petitioner began working at               
          Foxcroft on July 1, 1988.  Petitioner left some unmarketable                
          horses in Oregon and took four horses to Virginia.  Petitioner              
          intended to have the horses she left behind shipped to her to               
          sell after they attained marketable age.                                    
               Petitioner was injured in September 1988.  She suffered from           
          reflex sympathetic dystrophy and could not complete her duties              
          as headmistress of Foxcroft.  In January 1989, the Foxcroft board           
          of directors relieved petitioner of her position.  Petitioner               
          entered into a termination agreement with Foxcroft on                       
          February 12, 1989.                                                          
          C.   Petitioner's Post-Foxcroft Activities                                  
               Petitioner lived at Salem Farm in Upperville, Virginia, from           
          March to May 1989.  Petitioner went to her farm in Oregon twice             
          between January and May 1989.                                               
               In May 1989, petitioner permanently returned to her farm.              
          Petitioner gave two horses to Gerth Christensen (Christensen) in            
          August 1989.  The record does not indicate why petitioner gave              
          the horses to Christensen.                                                  
               From 1990 until the time of trial petitioner received                  
          pension payments, completed some consulting contracts, and taught           

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