In re Raejean S. Bonham dba World Plus
Bankruptcy No. F95-00897
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Strictly speaking, the federal government's case against Defendant Raejean S. Bonham is not a part of the bankruptcy proceedings. But because it is closely related, and because the outcome of the case may have implications for tvarious bankruptcy adversary cases, the indictment is set out in full here.

Joseph S. Beck
Senior Litigation Counsel
U.S. Department of Justice
Criminal Division, Fraud Section
PO Box 28188, Central Station
Washington, D.C. 20038

(202) 514-0630

UNITED STATES OF AMERICA, Plaintiff, vs. RAEJEAN S. BONHAM, Defendant.

Case No. A97-115 CR (HRH) Counts 1-53 Mail Fraud Violation of 18 U.S.C. §1341 Counts 54-61 Money Laundering Violation of 18 U.S.C. §1956(a)(1)(A)(i) Counts 62-79 Violation of Engaing in Monetary Transactions 18 U.S.C. §1957

The Grand Jury charges that at all times material Indictment:

1. The defendant, Raejean S. Bonham, was a resident of Fox, Alaska.

2. World Plus, Inc. (World Plus) was an Alaska corporation and had its registered office in Fairbanks, Alaska. Bonham was its sole shareholder, and the president, secretary, treasurer and director of World Plus. The business of World Plus was to sell to the public discounted airline tickets obtained from ticket brokers.

3. World Plus had, at different times, checking accounts at Key Bank of Alaska and Denali State Bank and a cash management account at Merrill Lynch.

4. Atlantic Pacific Funding Corporation (Atlantic Pacific) was a Nevada corporation with its registered office in Carson City, Nevada. Bonham was its sole shareholder, and the president, secretary, treasurer and director of Atlantic Pacific.

5. Atlantic Pacific had a checking account at First National Bank of Anchorage.

6. A Ponzi or pyramid scheme is a scheme whereby its operator uses money obtained from a later investor to pay earlier victims, thus creating - and reinforcing - a belief that the victim's "investments" are profitable.

7. Beginning in or about 1989 through 1995, the defendant Raejean S. Bonham, as part of a Ponzi or pyramid scheme offered and sold to individual investors interest-bearing contracts.

8. The State of Alaska, through the Alaska Securities Act, requires the registration of the offer and sale of interest bearing contracts and regulates such transactions. Prior to the offer or sale of such interest bearing contracts an individual or entity could request an exemption from registration under certain circumstances.

9. The defendant Raejean S. Bonham, on behalf of World Plus, filed a Notice of Exempt Offering and was granted an exemption from registration by the State of Alaska on three occasions, those being March 3, 1993, May 24, 1994, and July 17, 1995.

10. A ticket broker is a individual or business having a pool of travelers desiring to ell their airline frequent flyer miles obtained through participation in an airline frequent flyer program and also having an outlet, such as World Plus, to sell the tickets. Frequent flyer tickets usually sell for less than the best fare an airline offers.

11. Delta Air Lines, Inc. (Delta) was a domestic and international air carrier operating in Interstate commerce.

12. On or about May 21, 1993, Delta sought and obtained a Temporary Restraining Order and Preliminary Injunction restraining various ticket brokers and others, including Raejean S. Bonham and World Plus, Inc., acting in concert with them, from dealing in Delta Frequent Flyer Award Certificates and tickets.

13. On or about September 26, 1993, Delta obtained a Permanent Injunction prohibiting Bonham and World Plus from dealing in Delta tickets.

14. On or about December 19, 1995, an involuntary bankruptcy proceeding was initiated against Bonham and World Plus. Over 1,100 creditors have filed claims against World Plus and Bonham in an amount exceeding fifty million dollars for losses incurred in their investments with Bonham, World Plus and Atlantic Pacific.

15. From in or about 1989, and continuing through December 1995, the exact dates being unknown to the Grand Jury, in the District of Alaska and elsewhere, the defendant Raejean S. Bonham and others known and unknown to the Grand Jury, devised and intended to devise a scheme and artifice to defraud and to obtain money and property, namely, investments and loans, by means of false and fraudulent pretenses, representations and promises.

It was a part of the scheme and artifice that:

16. Beginning in or about 1984 and continuing through December 1995, the exact dates being unknown to the Grand Jury, defendant Raejean S. Bonham would resell frequent flyer tickets which she purchased through ticket brokers, who trafficked in frequent flyer award coupons.

17. Beginning in or about 1989 defendant Raejean S. Bonham would solicit money by offering individual investors the opportunity to become part of an "investment program" by purchasing "contracts" in $5,000 increments maturing in six to eight months and bearing a rate of return of 20% to 50% of their principal investment.

18. Defendant Raejean S. Bonham would falsely and fraudulently represent to investors that because World Plus was in the frequent flyer ticket business, banks would not lend money to the company thereby creating the need to raise money from individual investors.

19. Defendant Raejean S. Bonham would falsely and fraudulently represent to investors that the money invested, combined with that of other investors, would be used to purchase large blocks of frequent flyer miles from multi-national corporations, such as Sony or IBM, when in fact no such purchases would or could occur.

20. Defendant Raejean S. Bonham would falsely and fraudulently represent to investors that money they invested in the contracts was "guaranteed", bonded" and/or "insured" when in fact the monies invested were not guaranteed, bonded or insured.

21. Defendant Raejean S. Bonham would falsely and fraudulently represent to potential investors that there were a limited number or participants in the "investment program" and would conceal the fact there were several hundred investors.

22. Defendant Raejean S. Bonham would create and provide to the investor a one-page contract from either World Plus or Atlantic Pacific containing the terms of the investment including the principal amount, interest and maturity date. A number of contracts stated the principal amount was guaranteed, insured and/or bonded from loss when in fact it was not.

23. Defendant Raejean S. Bonham would, when a contract matured, encourage investors to "roll-over" the contract for another term, thereby keeping the cash required to maintain the scheme.

24. Defendant Raejean S. Bonham would fail to advise and concealed from potential investors that Delta Airlines had obtained a Court Order retraining her from dealing in Delta tickets.

25. DSRB would failed to advise and concealed from potential investors that the State of Alaska regulated the "contracts" she was selling.

26. Defendant Raejean S. Bonham would file false and fraudulent Notice of Exemption requests with the State of Alaska to avoid registration and regulation of the investor contracts and to conceal the nature and extent of her investment solicitations.

27. Defendant Raejean S. Bonham would use a portion of the investment for personal expenses and purchases.

28. Defendant Raejean S. Bonham would use a significant portion of the individual investor's investment to repay other investors thereby maintaining her Ponzi or pyramid scheme.

29. On or about the date specified in each count, in the District of Alaska and elsewhere, the Defendant Raejean S. Bonham, having devised the above described scheme and artifice to defraud and to obtain money and property by means of false and fraudulent pretenses, representations and promises, for the purpose of executing the scheme and artifice, did knowingly cause the following items to be placed in an authorized depository for mail to be sent and delivered by the United States Postal Service according to the directions thereon from Fairbanks, Alaska to the person and location specified in each count.

Count	Date	Victim	Item
1	4/14/95	Clara Evanson	Contract delivered by mail to Anchorage, Alaska
2	5/1/95	Clara Evanson	Contract delivered by mail to Anchorage, Alaska
3	3/9/95	Gertrude Braund	Contract delivered by mail to Anchorage, Alaska
4	5/13/95	Gertrude Braund	Contract delivered by mail to Anchorage, Alaska
5	4/14/95	Vernal Schneider	Contract delivered by mail to Anchorage, Alaska
6	8/23/95	Wilbur Hooks	Contract delivered by mail to Anchorage, Alaska
7	4/8/95	Gary Stockly	Contract delivered by mail to Anchorage, Alaska
8	2/16/95	David D. Zimmerman	Contract delivered by mail to Anchorage, Alaska
9	4/30/95	David D. Zimmerman	Contract delivered by mail to Anchorage, Alaska
10	6/19/95	David D. Zimmerman	Contract delivered by mail to Anchorage, Alaska
11	10/11/95	David D. Zimmerman	Contract delivered by mail to Anchorage, Alaska
12	3/4/95	Barbara Carbajal	Contract delivered by mail to Lake Arrowhead, California
13	6/24/95	Sylvia A. McCormick	Contract delivered by mail to Concord, New Hampshire
14	8/1/95	Sylvia A. McCormick	Contract delivered by mail to Concord, New Hampshire
15	8/24/95	Sylvia A. McCormick	Contract delivered by mail to Concord, New Hampshire
16	3/24/95	Mark K. Harris	Two contracts delivered by mail to Anchorage, Alaska
17	5/3/95	Mark K. Harris	Contract delivered by mail to Anchorage, Alaska
18	5/17/95	Mark K. Harris	$12,500 Atlantic Pacific check mailed to Anchorage, Alaska
19	5/19/95	Mark K. Harris	Contract delivered by mail to Anchorage, Alaska
20	6/19/95	Mark K. Harris	$10,000 Atlantic Pacific check mailed to Anchorage, Alaska
21	2/6/95	Matthew Kluh	Contract delivered by mail to Olympia, Washington
22	2/13/95	Dean Haller	Contract delivered by mail to Chelan, Washington
23	10/9/95	Dean Haller	Contract delivered by mail to Chelan, Washington
24	12/7/95	Dean Haller	Contract delivered by mail to Chelan, Washington
25	2/24/95	Rolland Thompson	Contract delivered by mail to Olympia, Washington
26	6/9/95	Holly Hodson	Contract delivered by mail to Anchorage, Alaska
27	9/28/95	Holly Hodson	$15,000 note delivered by mail to Anchorage, Alaska
28	8/1/95	Robert Koon	$30,000 note delivered by mail to Eagle River, Alaska
29	8/21/95	Robert Koon	Contract delivered by mail to Eagle River, Alaska
30	11/3/95	Robert Koon	Contract delivered by mail to Eagle River, Alaska
31	8/9/95	Robert G. Taylor	$2,000 Atlantic Pacific check delivered by mail to Branch, Michigan
32	9/21/95	Robert G. Taylor	Contract delivered by mail to Branch, Michigan

30. On or about the date specified in each count, in the District of Alaska and elsewhere, Defendant Raejean S. Bonham having devised the above described scheme and artifice to defraud and to obtain money and property by false and fraudulent pretenses, representations and promises, for the purpose of executing the scheme and artifice, did knowingly cause to be delivered by ail, to Fairbanks, Alaska, according to direction thereon, the item described in each count from the person specified in each count.

Count	Date	Victim	Item
33	4/7/95	Clara Evanson	$40,000 check mailed to Fairbanks, Alaska
34	2/10/95	Gertrude Braund	$20,000 check mailed to Fairbanks, Alaska
35	3/27/95	Gary Stockly	$10,000 check mailed to Fairbanks, Alaska
36	10/27/95	Gary Stockly	$20,000 check mailed to Fairbanks, Alaska
37	2/9/95	David D. Zimmerman	$10,000 check mailed to Fairbanks, Alaska
38	4/20/95	David D. Zimmerman	$10,000 check mailed to Fairbanks, Alaska
39	5/22/95	David D. Zimmerman	$5,000 check mailed to Fairbanks, Alaska
40	10/4/95	David D. Zimmerman	$40,000 check mailed to Fairbanks, Alaska
41	2/17/95	Barbara Carbajal	$10,000 check mailed to Fairbanks, Alaska
42	3/1/95	Mark K. Harris	$20,000 check mailed to Fairbanks, Alaska
43	4/19/95	Mark K. Harris	$20,000 check mailed to Fairbanks, Alaska
44	10/13/95	Mark K. Harris	$12,500 check mailed to Fairbanks, Alaska
45	10/27/95	Mark K. Harris	$20,000 check mailed to Fairbanks, Alaska
46	1/24/95	Matthew Kluh	$2,500 check mailed to Fairbanks, Alaska
47	2/6/95	Dean Haller	$10,000 check mailed to Fairbanks, Alaska
48	2/10/95	Rolland Thompson	$30,000 check mailed to Fairbanks, Alaska
49	9/5/95	Robert G. Taylor	$5,000 check mailed to Fairbanks, Alaska
50	10/10/95	Robert G. Taylor	$2,500 check mailed to Fairbanks, Alaska

All in violation of Title 18, United States Code, section 1341.

32. on or about the dates specified below in each count, in the District of Alaska, Defendant Raejean S. Bonham did knowingly conduct and attempt to conduct a financial transaction affecting interstate and foregin commerce, to wit: payments to investors as described in each count, which involved the proceeds of a specified unlawful activity, that is, mail fraud in violation of Title 18 U.S.C., section 1342 as described in paragraphs 1 through 28 of Count I of this indictment, with the intent to promote the carrying on of specified unlawful activity, to wit: mail fraud in violation of Title 18 U.S.C. section 1341, and that white conducting and attempting to conduct such financial transaction knew that the property involved in the financial transaction represented the proceeds of some form of unlawful activity.

Count	Date	Financial Transaction
54	5/10/95	$5,000 check payable to Cody Leonard or Cindy Leonard Marsh
55	7/7/95	$7,500 check payable to Cody Leonard or Cindy Leonard Marsh
56	7/7/95	$7,500 check payable to Cody Leonard or Cindy Leonard Marsh
57	5/17/95	$12,500 Atlantic Pacific check payable to Mark K. Harris or Rebecca Eames
58	6/19/95	$10,000 Atlantic Pacific check payable to Mark Harris or Rebecca Eames
59	11/20/95	$5,000 World Plus check to Dean & Hedi Haller
60	8/9/95	$2,000 Atlantic Pacific check payable to Robert or Betty Taylor
61	11/30/95	$5,000 cashiers check payable to World Plus, Inc. or Robert Koon

All in violation of Title 18, United States Code, section 1956(a)(1)(A)(i).

33. On or about the dated specified below in each count, in the District of Alaska, Defendant Raejean S. Bonham did knowingly engage in a monetary transaction, affecting interstate commerce, in criminally derived property of a value greater than $10,000, that is, the transfer of funds by check from the account of Rajean S. Bonham d.b.a Atlantic Pacific Funding Corporation at First National Bank of Anchorage to the account of World Plus, Inc., Raejean S. Bonham at Key Bank of Alaska in the amount specified in each count, such property having been derived from a specified unlawful activity that is mail fraud in violation of Title 18 U.S.C., section 1341 as described in paragraphs 1 through 28 of this indictment.

Count	Date	Amount
62	2/8/95	$15,000 check, check number 2370
63	2/10/95	$30,000 check, check number 2386
64	2/17/95	$18,000 check, check number 2426
65	2/22/95	$20,000 check, check number 2461
66	6/28/95	$15,000 check, check number 3272
67	6/30/95	$35,000 check, check number 3307
68	7/6/95	$15,000 check, check number 3317
69	7/11/95	$30,000 check, check number 3339
70	7/14/95	$15,000 check, check number 3404
71	7/14/95	$15,000 check, check number 3405
72	7/14/95	$15,000 check, check number 3415
73	7/17/95	$15,000 check, check number 3416
74	7/18/95	$15,000 check, check number 3438
75	7/19/95	$20,000 check, check number 3447
76	7/20/95	$30,000 check, check number 3452
77	7/20/95	$30,000 check, check number 3453
78	7/21/95	$30,000 check, check number 3472
79	7/21/95	$30,000 check, check number 3473

All in violation of Title 18, United States Code, section 1957.

Mary C. Spearing, Chief Fraud Section, Criminal Division U.S. Department of Justice	A TRUE BILL
/s/ Joseph S. Beck Senior Litigation Counsel DATED the 22nd day of October, 1997	/s/ Presiding Grand Juror

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