Cabot Christianson, Esq

In re Raejean S. Bonham dba World Plus
Bankruptcy No. F95-00897
Unofficial Web Site

Among the debtor's records, the trustee found a very large number of checks drawn to payees who could not be identified either as investors or as vendors of frequent flier tickets. What all of the checks have in common is that they were negotiated through Fairbanks-are bars. The trustee has filed two complaints against both the persons the trustee believes were involved in those efforts and the bars cashing those checks to recover those monies.

Cabot Christianson, Esq.
BUNDY & CHRISTIANSON
911 W. 8th Avenue, Suite 302
Anchorage, AK 99501
(907) 258-6016

Attorneys for Trustee

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF ALASKA

UNITED STATES BANKRUPTCY COURT
DISTRICT OF ALASKA

In Re:

)

RAEJEAN BONHAM, aka JEAN BONHAM, aka

)

JEANNIE BONHAM dba WORLD PLUS

) Bankruptcy No. F95-00897-HAR

Debtor.

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_____________________________________

)

)

LARRY D. COMPTON, TRUSTEE,

)

Plaintiff,

)

)

v.

)

)

AVAN BREES; CHRISTIAN BLANKENSHIP, BEVERLY KRAMME; PAN-AMERICAN CONSORTIUM, INC., d/b/a BIG I BAR; JOHN SEXTON; DONALD BURNETT d/b/a MECCA BAR; ABIE NEUBAUER, INC. d/b/a BOATEL BAR; JOHN A NEUBAUER AND ANNIE L. NEUBAUER; G.B. BUSH; J.B. BUSH; PHIL MCGROIN; CLINTON JAMESON; MADORI GREEN; A. GOODWIN; AWARD TRAVEL; TICKETS ARE US; WORLDWIDE TRAVEL; CREATIVE TRAVEL; ONE STOP TRAVEL COMPANY; FIVE STARR COUPONS; ALASKA PLUS, INC.; DON JENNINGS; and DEAN WITTER REYNOLDS, INC.,

)
)
)
)
)
)
)
) Case No. F95-00897-424 HAR
) Bancap No. 96-4550
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)

Defendants.

)

AMENDED COMPLAINT

1. This is an action to recover certain prepetition payments made by debtor to defendants, as part of a Ponzi scheme and a scheme to defraud, as follows.

To defendant Christian Blankenship:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Federal fraud - interest (_1 year)	Federal fraud - principal (_1 year)	State fraud (>1 year)	Usury Penalty	Total
#1334 5/12/94	$0 (principal)						0
	$1,000 (interest)				1,000	1,000	2,000
#7390 3/3/95	$0 (principal)						0
	$1,000 (interest)		1,000			1,000	2,000
TOTALS		$ 0	$ 1,000	$ 0	$ 1,000	$ 2,000	$ 4,000

To defendant Beverly Kramme:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Federal fraud - interest (_1 year)	Federal fraud - principal (_1 year)	State fraud (>1 year)	Usury Penalty	Total
#2027 11/23/94	$0 (principal)						0
	$12,000 (interest)				12,000	12,000	24,000
TOTALS		$ 0	$ 0	$ 0	$ 12,000	$ 12,000	$ 24,000

To defendant Alaska Plus, Inc.:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Federal fraud - interest (_1 year)	Federal fraud - principal (_1 year)	State fraud (>1 year)	Usury Penalty	Total
#5228 8/25/92	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#5445 12/18/92	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#5444 12/21/92	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#5446 12/23/92	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#468 8/24/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#470 8/30/93	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#469 8/31/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#1184 3/23/94	$0 (principal)						0
	$5,000 (interest)				5,000	5,000	10,000
#1183 3/29/94	$0 (principal)						0
	$5,000 (interest)				5,000	5,000	10,000
#2028 11/22/94	$0 (principal)						0
	$10,000 (interest)				10,000	10,000	20,000
#2560 3/20/95	$0 (principal)						0
	$7,000 (interest)		7,000			7,000	14,000
TOTALS		$ 0	$ 7,000	$ 0	$ 50,000	$ 27,000	$ 84,000

To defendant G.B. Bush:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Sec. 548 fraud - interest (_1 year)	Sec. 548 fraud - principal (_1 year)	Other fraud	Usury Penalty	Total
#126 3/30/93	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#124 4/6/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#125 4/8/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#156 4/8/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#161 4/9/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#157 4/12/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#158 4/12/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#159 4/16/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#160 4/16/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#259 6/1/93	$0 (principal)						0
	$3,000 (interest)				3,000		3,000
#258 6/7/93	$0 (principal)						0
	$3,000 (interest)				3,000		3,000
#292 6/18/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#293 6/21/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#294 6/24/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#410 8/2/93	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#411 8/6//93	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#409 8/16/93	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#408 8/18/93	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#654 10/27/93	$0 (principal)						0
	$7,000 (interest)				7,000		7,000
#655 11/3/93	$0 (principal)						0
	$5,500 (interest)				5,500		5,500
TOTALS		$ 0	$ 0	$ 0	$ 86,000	$ 0	$ 86,000

To defendant J.B.Bush:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Federal fraud - interest (_1 year)	Federal fraud - principal (_1 year)	State fraud (>1 year)	Usury Penalty	Total
#862 1/18/94	$0 (principal)						0
	$3,000 (interest)				3,000	3,000	6,000
#864 1/21/94	$0 (principal)						0
	$3,000 (interest)				3,000	3,000	6,000
#863 1/24/94	$0 (principal)						0
	$3,000 (interest)				3,000	3,000	6,000
#861 1/28/94	$0 (principal)						0
	$3,000 (interest)				3,000	3,000	6,000
TOTALS		$ 0	$ 0	$ 0	$ 12,000	$ 12,000	$ 24,000

To Defendant Phil McGroin:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Sec. 548 fraud - interest (_1 year)	Sec. 548 fraud - principal (_1 year)	Other fraud	Usury Penalty	Total
#1046 2/28/94	$0 (principal)						0
	$5,000 (interest)				5,000	5,000	10,000
TOTALS		$ 0	$ 0	$ 0	$ 5,000	$ 5,000	$ 10,000

To Defendant Clinton Jameson:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Sec. 548 fraud - interest (_1 year)	Sec. 548 fraud - principal (_1 year)	Other fraud	Usury Penalty	Total
#407 7/30/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#524 9/13/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#526 9/15/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#525 9/22/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#560 9/29/93	$0 (principal)						0
	$7,500 (interest)				7,500		7,500
#1315 5/5/94	$0 (principal)						0
	$6,000 (interest)				6,000	6,000	12,000
TOTALS		$ 0	$ 0	$ 0	$ 33,500	$ 6,000	$ 39,500

To Defendant Madori Green:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Sec. 548 fraud - interest (_1 year)	Sec. 548 fraud - principal (_1 year)	Other fraud	Usury Penalty	Total
#769 12/10/93	$0 (principal)						0
	$6,000 (interest)				6,000		6,000
#767 12/13/93	$0 (principal)						0
	$2,000 (interest)				2,000		2,000
#768 12/22/93	$0 (principal)				2,000	2,000	4,000
	$0 (interest)						0
TOTALS		$ 0	$ 0	$ 0	$ 10,000	$ 2,000	$ 12,000

To defendant A. Goodwin:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Sec. 548 fraud - interest (_1 year)	Sec. 548 fraud - principal (_1 year)	Other fraud	Usury Penalty	Total
#959 2/10/94	$0 (principal)						0
	$2,500 (interest)				2,500	2,500	5,000
#960 2/16/94	$0 (principal)						0
	$2,500 (interest)				2,500	2,500	5,000
#961 2/18/94	$0 (principal)						0
	$2,500 (interest)				2,500	2,500	5,000
#962 2/24/94	$0 (principal)						0
	$2,500 (interest)				2,500	2,500	5,000
TOTALS		$ 0	$ 0	$ 0	$ 10,000	$ 10,000	$ 20,000

To defendant Avan Brees:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Sec. 548 fraud - interest (_1 year)	Sec. 548 fraud - principal (_1 year)	Other fraud	Usury Penalty	Total
#2398 4/30/90	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#3447 5/23/91	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#3875 8/30/91	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#3933 9/6/91	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#3934 9/30/91	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#5230 8/26/92	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#5937 10/14/92	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#6010 11/17/92	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#5316 11/30/92	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#522 9/3/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#1045 2/25/94	$0 (principal)						0
	$5,000 (interest)				5,000	5,000	10,000
#3102 6/13/95	$0 (principal)						0
	$6,000 (interest)		6,000			6,000	12,000
#3555 8/10/95	$0 (principal)						0
	$5,000 (interest)		5,000			5,000	10,000
TOTALS		$ 0	$ 11,000	$ 0	$ 47,500	$ 16,000	$ 74,500

To Defendant Don Jennings:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Sec. 548 fraud - interest (_1 year)	Sec. 548 fraud - principal (_1 year)	Other fraud	Usury Penalty	Total
#2397 5/1/90	$0 (principal)						0
	$2,5000 (interest)				2,500		2,500
#3448 5/23/91	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#3876 8/20/91	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#5938 9/9/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#523 9/9/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#653 10/26/93	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
#980 2/18/94	$0 (principal)						0
	$1,000.04 (interest)				1,000	1,000	2,000
#1893 10/28/94	$0 (principal)						0
	$1,000 (interest)				1,000	1,000	2,000
#3103 6/9/95	$0 (principal)						0
	$6,000 (interest)		6,000			6,000	12,000
#3556 8/8/95	$0 (principal)						0
	$5,000 (interest)		5,000			5,000	10,000
#3586 8/17/95	$0 (principal)						0
	$1,000 (interest)		1,000			1,000	2,000
#6011 10/28/92	$0 (principal)						0
	$5,000 (interest)				5,000		5,000
TOTALS		$ 0	$ 12,000	$ 0	$ 29,500	$ 14,000	$ 55,500

To Defendant Avan Breeze and/or Defendant Don Jennings:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Sec. 548 fraud - interest (_1 year)	Sec. 548 fraud - principal (_1 year)	Other fraud	Usury Penalty	Total
#2979 12/5/90	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#3842 8/6/91	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#4644 4/2/92	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#4957 6/3/92	$0 (principal)						0
	$7,500 (interest)				7,500		7,500
#4975 6/15/92	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#4999 6/19/92	$0 (principal)						0
	$7,500 (interest)				7,500		7,500
#5229 9/1/92	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#5315 11/20/92	$0 (principal)						0
	$2,500 (interest)				2,500		2,500
#5366 12/21/92	$0 (principal)						0
	$7,500 (interest)				7,500		7,500
TOTALS		$ 0	$ 0	$ 0	$ 37,500	$ 0	$ 37,500

To Defendant Five Starr Coupons:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Sec. 548 fraud - interest (_1 year)	Sec. 548 fraud - principal (_1 year)	Other fraud	Usury Penalty	Total
#2117 12/16/94	$0 (principal)						0
	$3,000 (interest)				3,000	3,000	6,000
#2118 12/19/94	$0 (principal)						0
	$4,600 (interest)		4,600			4,600	9,200
#2119 12/29/94	$0 (principal)						0
	$5,400 (interest)		5,400			5,400	10,800
#2120 1/6/95	$0 (principal)						0
	$5,500 (interest)		5,500			5,500	11,000
#2121 1/11/95	$0 (principal)						0
	$4,500 (interest)		4,500			4,500	9,000
TOTALS		$ 0	$ 20,000	$ 0	$ 3,000	$ 23,000	$ 46,000

To Defendant One Stop Travel Company:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Sec. 548 fraud - interest (_1 year)	Sec. 548 fraud - principal (_1 year)	Other fraud	Usury Penalty	Total
#1878 10/24/94	$0 (principal)						0
	$3,775 (interest)				3,775	3,775	7,550
#2029 11/23/94	$0 (principal)						0
	$5,250 (interest)				5,250	5,250	10,500
#2030 12/1/94	$0 (principal)						0
	$4,750 (interest)				4,750	4,750	9,500
TOTALS		$ 0	$ 0	$ 0	$ 13,775	$ 13,775	$ 27,550

To Defendant Creative Travel:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Sec. 548 fraud - interest (_1 year)	Sec. 548 fraud - principal (_1 year)	Other fraud	Usury Penalty	Total
#1877 10/24/94	$0 (principal)						0
	$7,350 (interest)				7,350	7,350	14,700
#7217 11/18/94	$0 (principal)						0
	$4,100 (interest)				4,100	4,100	8,200
TOTALS		$ 0	$ 0	$ 0	$ 11,450	$ 11,450	$ 22,900

To Defendant Worldwide Travel:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Sec. 548 fraud - interest (_1 year)	Sec. 548 fraud - principal (_1 year)	Other fraud	Usury Penalty	Total
#1841 10/10/94	$0 (principal)						0
	$7,650 (interest)				7,650	7,650	15,300
TOTALS		$ 0	$ 0	$ 0	$ 7,650	$ 7,650	$ 15,300

To Defendant Tickets Are Us:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Sec. 548 fraud - interest (_1 year)	Sec. 548 fraud - principal (_1 year)	Other fraud	Usury Penalty	Total
#1671 9/9/94	$0 (principal)						0
	$2,175 (interest)				2,175	2,175	4,350
#1674 9/16/94	$0 (principal)						0
	$1,050 (interest)				1,050	1,050	2,100
#1750 9/26/94	$0 (principal)						0
	$3,225 (interest)				3,225	3,225	6,450
TOTALS		$ 0	$ 0	$ 0	$ 6,450	$ 6,450	$ 12,900

To Defendant Award Travel:

Debtor's check # and clearing date	Amount of check	LEGAL THEORY OF RECOVERY
		Preference	Sec. 548 fraud - interest (_1 year)	Sec. 548 fraud - principal (_1 year)	Other fraud	Usury Penalty	Total
#1670 9/6/94	$0 (principal)						0
	$3,075 (interest)				3,075	3,075	6,150
#1749 10/3/94	$0 (principal)						0
	$3,025 (interest)				3,025	3,025	6,050
TOTALS		$ 0	$ 0	$ 0	$ 6,100	$ 6,100	$ 12,200

Jurisdiction

2. This court has subject matter jurisdiction under 28 U.S.C. ß 1334(b). This is a core proceeding under 28 U.S.C. ß 157(b)(2)(F).

Parties

3. Plaintiff is the duly appointed and acting trustee in In re: Raejean Bonham, aka Jean Bonham, aka Jeannie Bonham, dba World Plus, Case No. F95-00897 HAR in this court, which case was commenced by the filing of an involuntary petition on December 19, 1995. An order for relief was thereafter entered. Plaintiff has standing to bring this action.

4. The bankruptcy estate in the above-named main case includes the rights, assets, claims and avoiding powers of the dissolved corporations World Plus, Inc., and Atlantic Pacific Funding Corporation. Alternatively, Trustee, as sole shareholder of those dissolved corporations, has authority to prosecute those rights, claims, and avoiding powers nominally or actually held by those dissolved corporations. In either event, the term Debtor herein refers both to the individual and the dissolved corporations.

5. To the extent that Raejean Bonham, World Plus, Inc., and Atlantic Pacific Funding Corporations are found to be distinct legal entities, (a) claims held by one entity against Defendants may not be set off against another entity, and (b) Defendants' giving value to one entity is not value as to the other entity.

6. The debtor, Raejean Bonham, operated a Ponzi scheme individually and through her wholly owned corporations, World Plus, Inc. and Atlantic Pacific Funding Corporation, in which she induced persons to loan money to her and her corporations for short terms at high interest rates. Investor loans were generally for six to eight months at 20% or 50% respectively, though certain investors received 50% return in approximately three to six months.

The Individual Defendants

7. Defendant Avan Brees is a resident of Fairbanks, Alaska. Brees began investing with the debtor not later than 1989. Brees is the majority shareholder of defendant Alaska Plus, Inc., an Alaska corporation, and from time to time, invested and received payments from the debtor as Alaska Plus, Inc. Brees also purchased investment contracts from the debtor and her corporations jointly with Don Jennings.

8. Defendant Beverly Kramme and defendant Christian Blankenship are residents of Fairbanks, Alaska.

9. Defendant Donald Jennings is a resident of Fairbanks, Alaska. Jennings began investing with the debtor not later than 1989. Jennings also purchased investment contracts from the debtor and her corporations jointly with Avan Brees.

Fictitious Payees

10. Defendants G.B. Bush, J.B. Bush, Phil McGroin, Clinton Jameson, Madori Green, A. Goodwin, Award Travel, Tickets Are Us, Worldwide Travel, Creative Travel, One Stop Travel Company, Five Starr Coupons, received checks from Atlantic Pacific Funding Corporation on the dates and in the amounts identified in paragraph 1.

11. Upon information and belief Defendants G.B. Bush, J.B. Bush, Clinton Jameson, Madori Green, A. Goodwin, Award Travel, Tickets Are Us, Worldwide Travel, Creative Travel, One Stop Travel Company, Five Starr Coupons, (the "Fictitious Payees") do not exist but are aliases of defendants Brees and Jennings under which they received payments from Atlantic Pacific or World Plus. In the event that one or more of the Fictitious Payees are actual persons, the trustee reserves the right to amend this complaint to allege additional causes of action against them.

The Immediate Transferees

12. Defendants Brees, Jennings, and Alaska Plus, Inc., engaged in a pattern of cashing checks made payable to fictitious payees at local businesses. A summary of where the checks identified in Paragraph 1 were cashed is attached as Exhibit A hereto.

13. Defendant John Sexton is a resident of Fairbanks, Alaska and is the majority shareholder of defendant Pan-American Consortium, Inc. which operates the Big I Bar in Fairbanks, Alaska. From time to time Defendant Sexton, or his employees, would cash checks issued by the debtor or her corporations to fictitious payees, including but not limited to G.B. Bush, Clinton Jameson, Madori Green, J.B. Bush, A. Goodwin, Phil McGroin, Award Travel, Tickets Are us, Award Travel, One Stop Travel Company, and Five Starr Coupons.

14. Upon information and belief, Pan-American Consortium, Inc. is the alter ego and mere instrumentality of John Sexton.

15. Defendant Donald Burnett is also known as Deke Burnett, a resident of Fairbanks, Alaska, and owner of the Mecca Bar located in Fairbanks, Alaska. Defendant Burnett was an investor in World Plus, Inc. and Atlantic Pacific Funding Corporation.

16. Defendant Abie Neubauer, Inc. is an Alaska corporation doing business as the Boatel Bar in Fairbanks Alaska.

17. Defendants Jon A. Neubauer and Annie L. Neubauer are residents of Fairbanks, Alaska, and each owns 50% of the stock of defendant Abbie Neubauer, Inc. From time to time Defendants Jon A. Neubauer and Annie L. Neubauer, or their employees, would cash checks issued by the debtor or her corporations to fictitious payees, including but not limited to G.B. Bush, Clinton Jameson, Madori Green, J.B. Bush, A. Goodwin, Phil McGroin, Award Travel, Tickets Are Us, Award Travel, One Stop Travel Company, and Five Starr Coupons.

18. Upon information and belief, Abbie Neubauer, Inc. is the alter ego and mere instrumentality of defendants Jon A. Neubauer and Annie L. Neubauer.

19. Defendant Dean Winter Reynolds, Inc. (Dean Winter) is a corporation doing business in the State of Alaska. Defendant Dean Winter cashed Atlantic Pacific Funding Corp. Check Nos. 159 and 410 made payable to G.B. Bush. Defendant Avan Brees maintains Account No. 143-015340-063 at defendant Dean Witter.

General Allegations

20. Prior to the filing of the involuntary petition in this case, debtor engaged in a Ponzi scheme. That is, debtor borrowed money from defendants and other individuals on a short-term, high-interest basis. Repayment terms varied from loan to loan and from investor to investor, but typical repayment terms were a 50% return on principal in eight months. The primary source of repayment of such loans was loans from new investors, not profits from a legitimate business enterprise. Debtor's Ponzi scheme grew until debtor was unable to attract sufficient new investors to meet the demands of investors whose loans had matured. At that point, the pyramid collapsed, leaving more than 1,000 investors unpaid. Those investors have filed proofs of claim in this court totalling approximately $50 million.

21. Defendants Avan Brees, Donald Jennings and Alaska Plus, Inc. entered into one or more contracts with debtor under which defendants lent money to debtor, and debtor agreed to repay such money at agreed-upon rates. At all times, the relationship between debtor and defendants was that of debtor and creditor.

22. Beginning in the spring of 1990, the Big I Bar, the Mecca Bar, and the Boatel Bar began cashing checks for defendants Brees, Jennings and/or Alaska Plus from the debtor and her corporations.

23. Beginning in the spring of 1993, the Big I Bar, the Mecca Bar, and the Boatel Bar began cashing checks from the debtor and her corporations, issued to the Fictitious Payees.

24. To the extent that Brees, Jennings, Alaska Plus, and the Fictitious Payees received payments from Atlantic Pacific, they are initial payees within the meaning of that term as used in 11 U.S.C. ß 550(a).

25. Defendants Brees, Jennings, Alaska Plus, and the Fictitious Payees received the payments identified in paragraph 1 as part of a Ponzi scheme.

26. Upon information and belief, the debtor wrote the checks to the Fictitious Payees identified in paragraph 1 as part of a fraudulent scheme to launder money to defendants Brees, Jennings, and Alaska Plus.

27. Defendants John Sexton, Pan-American Consortium d/b/a Big I Bar, Donald Burnett d/b/a the Mecca Bar, John and Annie Neubauer, and Abbie Neubauer, Inc. d/b/a the Boatel Bar aided, assisted, and further the debtor's Ponzi scheme and other fraudulent purposes by cashing the checks identified in paragraph 1 with knowledge of the Ponzi scheme and other fraudulent purposes.

28. For purposes of the checks identified in paragraph 1 that were cashed at their respective establishments, Defendants Sexton and Pan-American Consortium d/b/a Big I Bar, the Mecca Bar, and the Boatel Bar are immediate transferees of the payees within of that term as used in 11 U.S.C. ß 550(a)(2).

29. Defendant Sexton knew and acquiesced in Pan-American Consortium, d/b/a the Big I Bar, participation in the fraudulent scheme between the debtor and defendants Brees, Jennings and Alaska Plus.

30. Defendant Burnett knew and acquiesced in the Mecca Bar's participation in the fraudulent scheme between the debtor and defendants Brees, Jennings and Alaska Plus.

31. Defendants John and Annie Burnett knew and acquiesced in the Mecca Bar's participation in the fraudulent scheme between the debtor and defendants Brees, Jennings and Alaska Plus.

SECTION 548(a)(1)
FEDERAL FRAUDULENT CONVEYANCE CAUSE OF ACTION

32. With respect to each of the checks identified in paragraph 1 that cleared the debtor's bank account before December 19, 1994, the debtor intended to hinder, delay or defraud her creditors within the meaning of 11 U.S.C. ß 548(a)(1).

33. Defendants identified as payees in paragraph 1 are transferees of a fraudulent conveyances liable accordingly to the trustee under Section 550 for the checks each defendant received as identified in paragraph 1.

34. Defendants Pan-American Consortium d/b/a Big I Bar, Donald Burnett d/b/a the Mecca Bar, and Abbie Neubauer, Inc. d/b/a the Boatel Bar are liable as immediate transferees of the fictitious payees under 11 U.S.C. ß 550(a) for those checks identified in paragraph 1 that were cashed at their establishments, and in the amount of the checks cashed.

SECTION 548(a)(2)
FEDERAL FRAUDULENT CONVEYANCE CAUSE OF ACTION

35. With respect to each of the checks identified in Paragraph 1 that cleared the debtor's bank account before December 19, 1994, the debtor received less than a reasonably equivalent value in exchange for the respective transfers.

36. The debtor was or became insolvent at the time of making each of the checks described in the preceding paragraph.

37. Debtor also was engaged in a business for which any property remaining with her represented unreasonably small capital.

38. Debtor also intended to incur, or believed that she would incur, debts that would be beyond her ability to pay as such debts matured.

39. Those checks identified in Paragraph 1 that cleared the debtor's bank account before December 19, 1994, are voidable under 11 U.S.C. Section 548(a)(2), and the defendant payees are liable to the trustee under 11 U.S.C. ß 550 for the respective amounts identified in paragraph 1.

40. Defendants Pan-American Consortium d/b/a Big I Bar, Donald Burnett d/b/a the Mecca Bar, and Abbie Neubauer, Inc. d/b/a the Boatel Bar are liable as immediate transferees of the fictitious payees under 11 U.S.C. ß 550(a) for those checks identified in Paragraph 1 that were cashed at their establishments, and in the amount of the checks cashed.

STATE FRAUDULENT CONVEYANCE CAUSE OF ACTION
[AS 34.40.010]

41. With respect to each of the checks identified in Paragraph 1, the debtor paid checks with the actual intent to hinder, delay or defraud her creditors within the meaning of AS 34.40.010.

42. At all times relevant to this claim, up to and including the Petition Date, Delta Airlines, the Securities and Exchange Commission (SEC), and unpaid investors, were general unsecured creditors of the Debtor whose existence gives standing to the trustee under 11 U.S.C. ß 544(b) to assert this cause of action.

43. Each of the checks identified in Paragraph 1 are avoidable under ß 544(b), and the defendants payees are liable to the Trustee under 11 U.S.C. ß 550 for the respective amounts received for the respective amounts identified in paragraph 1.

44. Defendants Pan-American Consortium d/b/a Big I Bar, Donald Burnett d/b/a the Mecca Bar, and Abbie Neubauer, Inc. d/b/a the Boatel Bar are liable as immediate transferees of the fictitious payees under 11 U.S.C. ß 550(a) for those checks identified in Paragraph 1 that were cashed at their establishments, and in the amount of the checks cashed.

STATE FRAUDULENT CONVEYANCE ACTION
[State Common Law]

45. Each check identified in Paragraph 1 is also avoidable as a fraudulent conveyance under the common law of the State of Alaska.

46. At all times relevant to this claim, up to and including the Petition Date, Delta Airlines, the Securities and Exchange Commission (SEC), and unpaid investors, were general unsecured creditors of the Debtor whose existence gives standing to the trustee under 11 U.S.C. ß 544(b) to assert this cause of action.

47. Each of the checks identified in Paragraph 1 is avoidable under 11 U.S.C. ß 544(b) and the defendant payees are liable to the Trustee under 11 U.S.C. ß 550 for the respective amounts identified in paragraph 1.

48. Defendants Pan-American Consortium d/b/a Big I Bar, Donald Burnett d/b/a the Mecca Bar, and Abbie Neubauer, Inc. d/b/a the Boatel Bar are liable as immediate transferees of the fictitious payees under 11 U.S.C. ß 550(a) for those checks identified in Paragraph 1 that were cashed at their establishments, and in the amount of the checks cashed.

FEDERAL FAIR DEBT COLLECTION PRACTICES ACT
[28 U.S.C. SEC. 3304]

49. The Securities and Exchange Commission (SEC) has filed a proof of claim (No. 859) in the main case, and has filed litigation against Raejean Bonham, SEC v. Bonham, Case No. F96-0023 CIV, in the United States District Court for the District of Alaska. These claims represent a debt to the United States within the meaning of 28 U.S.C. ß 3304.

50. The checks identified in Paragraph 1 are avoidable under 28 U.S.C. ß 3301, et seq., including, but not limited to, Sections 3304(a) and 3304(b).

51. The SEC claim, and any other claim that may be filed by the United States government, gives standing to assert this cause of action under 11 U.S.C ß 544(b).

52. Each of the checks identified in Paragraph 1 is avoidable under 11 U.S.C. ß 544(b), and the defendants payees are liable to the Trustee under 11 U.S.C. ß 550 in the respective amounts identified in paragraph 1.

53. Defendants Pan-American Consortium d/b/a Big I Bar, Donald Burnett d/b/a the Mecca Bar, and Abbie Neubauer, Inc. d/b/a the Boatel Bar are liable as immediate transferees of the fictitious payees under 11 U.S.C. ß 550(a) for those checks identified in Paragraph 1 that were cashed at their establishments, and in the amount of the checks cashed.

AIDING AND ABETTING A FRAUDULENT CONVEYANCE

54. The debtor and defendants created a fraudulent scheme to allow Brees and Jennings to receive transfers from the debtor under the guise of fictitious names.

55. Defendants knowingly aided and abetted the fraud by cashing checks to fictitious payees at their establishments to fictitious payees identified in Paragraph 1, and in the amount stated therein.

56. At all times relevant to this claim, up to and including the Petition Date, Delta Airlines, the Securities and Exchange Commission (SEC), and unpaid investors, were general unsecured creditors of the Debtor whose existence gives standing to the trustee under 11 U.S.C. ß 544(b) to assert this cause of action.

57. As a proximate result of defendants' participation in the conspiracy to defraud, World Plus, Inc., Atlantic Pacific Funding Corporation, and their creditors were injured in an amount not less than $427,075 to be proved at trial.

58. Defendants are jointly and severally liable in an amount not less than $427,075.

CONSPIRING TO COMMIT FRAUDULENT CONVEYANCES

59. As alleged above, defendants conspired with the debtor and others to defraud World Plus, Inc., Atlantic Pacific Funding Corporation and its creditors, and gave knowing and substantial assistance to the commission of that fraud, to fraudulently obtain checks from a Ponzi scheme and launder the money under the guise of false identities.

60. At all times relevant to this claim, up to and including the Petition Date, Delta Airlines, the Securities and Exchange Commission (SEC), and unpaid investors, were general unsecured creditors of the Debtor whose existence gives standing to the trustee under 11 U.S.C. ß 544(b) to assert this cause of action.

61. As a proximate result of defendants' participation in the conspiracy to defraud, World Plus, Inc., Atlantic Pacific Funding Corporation, and their creditors were injured in an amount not less than $427,075 to be proved at trial.

62. Defendants are jointly and severally liable in an amount not less than $427,075.

VIOLATION OF RICO
(18 U.S.C. ß 1961 et seq.)

63. The knowing and intentional participation of defendants in a scheme to defraud World Plus, Inc., its employees, creditors and other members of the public, which fraudulent scheme was carried out and furthered by telephone conversations, facsimile transmissions, and letters sent through the United States' mail, constitute repeated violations of 18 U.S.C. ß 1342 relating to wire fraud and 18 U.S.C. ß 1341 relating to mail fraud, and further constitute acts of racketeering activity as that term is defined in 18 U.S.C. ß 1961(B)

64. Defendants are entities capable of holding a legal or beneficial interest in property, and they represent persons subject to Racketeer Influenced and Corrupt Organizations Acts (RICO) pursuant to 18 U.S.C. ß 1961(3).

65. The debtor, including her wholly owned corporations World Plus, Inc. and Atlantic Pacific Funding Corporation, at all times relevant to this action, were an enterprises as that term is defined in 18 U.S.C. ß 1961(4).

66. The defendants together with the debtor and her corporations, associated in fact from September 1994 through December 1995, which association in fact constituted an enterprise as defined in 18 U.S.C. ß 1961(4).

67. The activities of the enterprise resulting from the association in fact among defendants and the debtor included the participation in a Ponzi scheme and money laundering for the benefit of defendants Brees, Jennings, and Alaska Plus.

68. The instances of wire fraud, mail fraud and the issuance of securities committed by defendants were related to the activities of the debtor and to the association in fact formed between defendants and the debtor.

69. The wire fraud, mail fraud and the issuance of securities perpetrated by defendants and others on the debtor, its employees, creditors and others, constituted a pattern of racketeering activity consisting of more than two acts of racketeering activity, all of which occurred after the effective date of 18 U.S.C. ß 1961 et seq, and the last of which occurred within ten years after the commission of a prior racketeering activity as required by 18 U.S.C. ß 1961(5).

70. Defendants used income derived from the above described pattern of racketeering in the operation of the enterprises, the activities of which affect interstate commerce, in violation of 18 U.S.C. ß 1962(a).

71. Defendants conducted, guided, managed, directed, controlled, or participated in the conduct of each of the enterprises through the above described pattern of racketeering activity, including the issuance of securities and receiving funds as part of a Ponzi scheme, and laundering funds, which enterprise activities affect interstate commerce in violation of 18 U.S.C. ß 1962(c).

72. Defendants conspired together and with the debtor to violate 18 U.S.C. ß 1962(a) and (c) in violation of 18 U.S.C. ß 1962(d).

73. As a direct and proximate result of the forgoing violations of 18 U.S.C. ß 1962 by defendants, the debtor and her corporation has sustained injury to its business and property in an undetermined amount, but not less than $427,075, plus interest.

PUNITIVE DAMAGES

74. As described above, each of defendants' conduct was outrageous, malicious, or done with such reckless disregard and indifference of the interests of World Plus, Inc. and Atlantic Pacific Funding Corporation, its employees, creditors and members of the public, so as to constitute outrageous conduct.

75. In order to punish defendants and to deter them and others similarly situated from engaging in such a pattern of conduct, punitive damages should be awarded in favor of the trustee and against each defendant.

ADDITIONAL CHECKS NOT LISTED IN PARAGRAPH 1

There are or may be payments which Debtor made to or for the benefit of the Defendants but which are not listed on Exhibit 1. Additionally, there may other payments to persons, real or fictitious, that were for the benefit of defendants Brees, Jennings, or Alaska Plus. Trustee gives notice that the judgment sought herein may include such payments, and reserves the right to amend this complaint to add additional persons upon discovery. The trustee also gives notice of his reservation of rights to assert additional claims based on the extent and nature of defendants' fraudulent conduct as may be more fully developed through discovery in this action.

WHEREFORE, plaintiff prays for relief as follows:

A. Judgment against defendants on one or more of the theories of preference, Sec. 548 fraudulent conveyance, state fraudulent conveyance, Federal Debt Collection Act claims, usury, said judgment being, after adjustment for duplication, in the amounts as against the defendants as set forth in Paragraph 1 hereto,

B. Judgment against defendants, jointly and severally, for aiding and abetting a fraudulent scheme, and conspiring to commit fraudulent conveyances, in an amount to be proved at trial;

B. Judgment against defendants Pan-American Consortium, Inc. Donald Burnett, and jointly and severally together with the individual recipients for the total amounts paid to the Fictitious Payees as identified in Paragraph 1 as immediate transferees of fraudulent conveyances under the provisions of 11 U.S.C. ß 550(a); and for aiding and abetting a fraudulent scheme, and conspiring to commit fraudulent conveyances.

C. On the trustee's RICO Claim, judgment against the defendants jointly and severally, in an undetermined amount believed to be not less than $427,075 which sum is to be trebled under the provisions of 18 U.S.C. ß 1964(c), plus attorney's fees and costs.

D. Judgement directing repayment of all avoided transfers under 11 U.S.C. ß 550.

E. An express provision in said judgment that the judgment is entered without prejudice to the trustee's right to file separate litigation against Defendants for any payments not specifically listed in said paragraph 1.

F. Punitive damages as against each defendant as may be appropriate.

G. Costs, pre-judgment interest, and attorneys fees.

H. Such other relief as this court deems proper.

Respectfully submitted in Anchorage, Alaska, this day of January, 1998.

BUNDY & CHRISTIANSON
Attorneys for Trustee

By:
Cabot Christianson

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In Re:	)
RAEJEAN BONHAM, aka JEAN BONHAM, aka	)
JEANNIE BONHAM dba WORLD PLUS	) Bankruptcy No. F95-00897-HAR
Debtor.	)
_____________________________________	)
	)
LARRY D. COMPTON, TRUSTEE,	)
Plaintiff,	)
	)
v.	)
	)
AVAN BREES; CHRISTIAN BLANKENSHIP, BEVERLY KRAMME; PAN-AMERICAN CONSORTIUM, INC., d/b/a BIG I BAR; JOHN SEXTON; DONALD BURNETT d/b/a MECCA BAR; ABIE NEUBAUER, INC. d/b/a BOATEL BAR; JOHN A NEUBAUER AND ANNIE L. NEUBAUER; G.B. BUSH; J.B. BUSH; PHIL MCGROIN; CLINTON JAMESON; MADORI GREEN; A. GOODWIN; AWARD TRAVEL; TICKETS ARE US; WORLDWIDE TRAVEL; CREATIVE TRAVEL; ONE STOP TRAVEL COMPANY; FIVE STARR COUPONS; ALASKA PLUS, INC.; DON JENNINGS; and DEAN WITTER REYNOLDS, INC.,	) ) ) ) ) ) ) ) Case No. F95-00897-424 HAR ) Bancap No. 96-4550 ) ) ) ) )
Defendants.	)