In re Raejean S. Bonham dba World Plus
Bankruptcy No. F95-00897
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NOTE: The Trustee has filed the following Supplemental Declaration Regarding New Evidence in support of his Motion to Enforce Access to the Real Property in order to attempt to sell that property. Please also see the Supplemental Memorandum in Support of Access.

The same Declaration was filed in support of the Findings of Fact and Conclusions of Law submitted by the Trustee in his preference claim against Steve and Raejean Bonham.

This motion is scheduled to be heard by the bankrputcy court in Fairbanks on June 16, 1996 at 2:00 PM.


In Re:





) Bankruptcy No. F95-00897-HAR











) Adv Proc No. 95-00897-185-HAR

) Bancap No. 96-4298













LARRY D. COMPTON, being first duly sworn, states that:

1. I am the duly authorized and acting Chapter 7 Trustee in the main case and the plaintiff in this adversary proceeding. I am making this Declaration in both the preference action against the Bonhams (Case No. F95-00897-184) and the action for sale of their residence (Case No. F95-00897-185), since the facts it describes bear on issues in both cases.

2. The court will recall that during the second day of trial in this matter, on April 16, 1997, the debtor admitted for the first time to having control of business records not previously known to me or to the court (referred to in this Affidavit as "the April 16, 1997 Production").

3. I was able to obtain those records from the accountant who had possession of them and have completed a preliminary review. That review has disclosed documents which are relevant to issues in this adversary proceeding, which I describe in this Declaration.

Restitution Under Felony Conviction

4. The court will recall that the debtor has a prior felony conviction arising out of an indictment for misappropriation of postal funds to which she plead guilty on July 13, 1977. A copy of the federal court docket sheet is attached as Exhibit A.

5. Under the terms of the judgment of conviction, the debtor was required to make restitution to the United States Postal Service. Apparently, she was dilatory in making those payments, and the United States Postal Service turned the restitution claim over to CSC Credit Services, Inc. in Houston, Texas. A copy of CSC Credit's demand letter dated July 30, 1990 to the debtor was found among the April 16, 1997 Production, and a true and correct copy is attached to this Affidavit as Exhibit B.

6. A hand written note appears in the top center of Exhibit B reading "Paid by WP #2708 8/28/90." I have become familiar with the debtor's handwriting and can identify the written note as the debtor's writing.

7. Attached as Exhibit C is the debtor's letter to the U.S. Postal Service tendering payment; attached as Exhibit D is a receipt issued September 9, 1990 to "Sandra Bonham Raegan" for $12,534.99, as requested by the debtor in Exhibit C.

8. I have confirmed from the Quicken(TM) database I described at trial in Adversary F95-00897-184 HAR that the payment of the balance due on the debtor's restitution obligation was made on September 10, 1990 by check number 2708 in the amount of $12,534.99. A copy of the register for the period September 7 - 10, 1990 is attached as Exhibit E.

9. It is apparent from these records that the debtor made her final restitution payment of $12,534.99 using monies obtained from World Plus investors through the debtor's Ponzi scheme, more than thirteen years after pleading guilty to the felony indictment.

Initial Rent Payments to Allen Dale Cartwright

10. Based upon the debtor's representations to me and to the court, I had advised the court that I believed the two initial payments of $12,738.07 made by Steve Bonham and Raejean Bonham to Allen Dale Cartwright could be traced to Steve Bonham's withdrawal of retirement monies from the University of Alaska.

11. I sought by subpoena to the State of Alaska Department of Administration copies of the disbursement records for Steve Bonham's retirement monies. The State of Alaska's response is attached as Exhibit F. It shows the following disbursements were made to the Bonhams and deposited as follows:



Bank Account



S and S/Key Bank



S and S/Key Bank




12.I have been able to confirm the deposit of the $33,567.63 into the S & S Services account on February 16, 1989 from the Key Bank records for that account.

13. By contrast, the two payments to Allen Dale Cartwright of $12,738.07 were made out of the World Plus account of the debtor. A copy of the relevant pages of the handwritten check register is attached as Exhibit G; copies of the instruments themselves are attached as Exhibits H and I. All of these documents were found among the April 16, 1997 Production.

14. The initial two rent payments of $12,738.07 each under the Lease with Option to Purchase were paid with World Plus monies and not with Steve Bonham's retirement monies from the University of Alaska. Steve Bonham has much less equity in the Bonhams' residence than the trustee had formerly believed.

Transfers from S & S to World Plus

15. The debtor has repeatedly told the court that S & S Services regularly wrote checks back to World Plus to reimburse World Plus for World Plus monies expended for the personal benefit of Steve Bonham and Raejean Bonham.

16. I can find no evidence among either the April 16, 1997 Production or among the records in the Quicken database to support the debtor's claim that monies were regularly transferred from the Bonhams' S & S Services account to the World Plus account, either in 1989 or in any other year. I cannot find a single instance of such a transfer.

17. Because checks are still missing for some periods, even after receipt of the April 16, 1997 Production, and deposit detail is missing for several periods, I have not merely looked for S & S Services checks drawn to World Plus. Instead, I have attempted to match unitemized deposits to the World Plus account to checks from the S & S Services account, and unknown checks from the S & S Services account to unknown deposits to the World Plus account.

18. Taking a specific example, there is an unknown $15,000 item, check number 2718, which cleared the S & S Services account on February 28, 1989. (The payee of the item is unknown because the item is taken from a bank statement, the instrument itself is unavailable.) If those monies were transferred to the World Plus account, and since the transfer would be internal to Key Bank, I would expect to see a $15,000 deposit item in the World Plus account on February 27 or 28, 1989. A review of the deposit records for the World Plus account for the period February 23, 1989 to March 2, 1989 shows no deposit remotely in the range of $15,000.

19. While the unknown $15,000 item may possibly have been a disbursement to an investor, it is also possible it was for the purchase of a boat, motorcycle, vehicle or something else unrelated to World Plus. I have no way of knowing. I can only state that it was not deposited into the World Plus account. (If the $15,000 was paid to an investor, it is still further proof of the commingling of funds by the debtor.)

20. Even at that level of review, I am unable to find any instance in which monies were transferred from the S & S Services account to the World Plus account or the APFC account. As far as I can determine, all of the monies flowed in the opposite direction.

Additional Disbursements to or for the Benefit of Steve Bonham

21. Based upon my review of the records, and taking into account all disbursements and transfers to S & S Services, Steve Bonham, Raejean Bonham and Stephanie Bonham, but excluding

(a) transfers and disbursements in cash,

(b) transfers and disbursements through credit cards and

(c) credit card purchases for the benefit of Steve Bonham, Stephanie Bonham and Shane Bonham, where the credit card bills were paid by World Plus or World Plus, Inc.;

for the period December 19, 1989 to December 19, 1995, more than $600,000 was paid by World Plus to Steve Bonham and Raejean Bonham.

22. Payments were made to the Bonhams either by payment of their personal bills and obligations, or by transfer to the S & S Services account, which so far as I can discover was used exclusively for personal purposes.

23. On occasion, assets were purchased with World Plus monies and, when subsequently sold, the proceeds of the sale were directed to the S & S Services account. As an example, on October 6, 1988, the Bonhams purchased a 1984 Fuqua mobile home for $32,000. A copy of the Division of Motor Vehicles detail vehicle record is attached as Exhibit J.

24. The purchase price of the mobile home was $32,000. A copy of the Bill of Sale from ITT Commercial Finance Corp. is attached as Exhibit K.

25. The purchase price was paid as follows:

(a) $11,800 by direct payment from World Plus to Fairbanks Title Agency, the closing agent for the sale. A copy of check 1347 is attached as Exhibit L. A copy of Fairbanks Title's receipt is attached as Exhibit M.

(b) $17,000 by payment from World Plus to Steve Bonham by World Plus check number 1384, which appears to have been deposited into the S & S Services account and then re-issued to Fairbanks Title as S & S Services check number 3803. A copy of World Plus check number 1384 is attached as Exhibit N. A copy of Fairbanks Title's receipt is attached as Exhibit O.

(c) The balance by check from the S & S Services account.

26. As far as I can determine, at least $28,800 of the purchase price for the 1984 Fuqua mobile home came directly from World Plus.

27. The Bonhams sold the 1984 Fuqua mobile home in 1989 to Lewis Bratcher and Ruth Bratcher for $36,000. A copy of the Purchase Contract between them dated September 22, 1989 is attached as Exhibit P.

\28. The Bonhams established a collection account at Key Bank of Alaska, Account No. 71499491, to receive the installment payments contemplated by the purchase contract. A copy of the Annual Collection Statement for 1990 is attached as Exhibit Q.

29. From the collection account, I have confirmed that payments were disbursed to the S & S Services account, the personal account of the Bonhams. The deposits of $1,000 each can be found in the bank statements on or about the date of the payment shown in the Annual Collection statement, Exhibit Q.

30. The practical effect of the purchase and sale of the 1984 Fuqua was to move not less than $28,800, together with the profit of $4,000 realized on the sale of the mobile home to the Bratchers, from the World Plus account to the S & S Services account.

31. While Steve Bonham did earn some income from snow removal and other services (legible memoranda on deposited checks describe a total of $5,375 for snow removal, as shown on Exhibit R), the overwhelming majority of all of the monies deposited into the S & S Services account appear to trace back to distributions and disbursements from World Plus.

DATED at Anchorage, Alaska this _____ day of May, 1997.


SUBSCRIBED AND SWORN to before me this _____ day of May, 1997.

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