In re Raejean S. Bonham dba World Plus
Bankruptcy No. F95-00897
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The U.S. Securities and Exchange Commission obtained a judgment against the debtor in its civil action against the debtor, Securities and Exchange Commission v. Bonham, Case No. F96-00023 in the United States District Court, District of Alaska, for $2,710,546, representing disgorgement of ill-gotten gains. Consistently with its complaint, the SEC has agreed to subordinate its claim. The text of the stipulation follows.

UNITED STATES BANKRUPTCY COURT
DISTRICT OF ALASKA

In Re:

)

RAEJEAN BONHAM, aka JEAN BONHAM, aka

)

JEANNIE BONHAM individually and dba WORLD PLUS; WORLD PLUS, INC.; and ATLANTIC PACIFIC FUNDING CORPORATION,

) Bankruptcy No. F95-00897-HAR

Debtor.

) (Substantively Consolidated)

_____________________________________

) Chapter 7
 

STIPULATION RE: CLAIMS 859 AND 1111
(Securities and Exchange Commission)

Larry D. Compton, Trustee, and the Securities and Exchange Commission (SEC) agree as follows:

RECITALS:

1. The SEC filed two claims in this case, No. 859 and No. 1111. Claim No. 1111 amended No. 859. Attached hereto is a copy of Claim No. 1111.

2. Claim No. 1111 in the amount of $2,710,546 represent an order of disgorgement of the debtor's ill-gotten gains, according to the terms of the judgment attached hereto in SEC v. Bonham, No. F96-0023, in the United States District Court for the District of Alaska.

3. The judgment provides that it will be carried out in accordance with the provisions of the Bankruptcy Code and the proceedings in this main bankruptcy case.

4. This stipulation is entered into to allow the claim as to amount and status.

THE PARTIES THEREFORE AGREE AS FOLLOWS:
  1. Claim No. 859 shall be disallowed on the basis that it is amended by Claim No. 1111.
  2. Claim No. 1111 shall be allowed as a general unsecured claim in the amount of $2,710,548. However, such claim shall be subordinated to payment of the general unsecured creditors under Section 726(a)(2) and 726(a)(3).

    DATED: 11-3-98

    BUNDY & CHRISTIANSON
    Attorney for Trustee

    /s/ Cabot Christianson

    DATED: November 2, 1998

    SECURITIES AND EXCHANGE COMMISSION

    /s/ Karen G. Kwong
    District Trial Counsel

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