D

MICHAEL H. AHRENS (state Bar No. 44766)

GILMORE Y. DIEKMANN (state Bar No. 50400)
2 LILLIAN G. STENFELDT (State Bar No. 104929)
BRONSON, BRONSON & McKINNON
3 505 MontgoEery Street
San Francisco, california 94111-2514
.4 Telephone: (415) 996-4200
5 Attorneys for Petitioner
FEDERAL EXPRESS CORPORATION,
6 a Delaware corporation
7

B UNITED STATES BANKRUPTCY COURT

9 NORTHERN DISTRICT OF CALIFORNIA
]0

z
0
z
Z
11

12
In re
HAMILTON TAFT & COMPANY}
91 ~ aSE NO.1 07' 7
) LK
::s::: ~ a California corporation, ) Chapter 11
Ufo-= 13
1lIZ, )
:2: '"<:: «
- Debtor. ) INVOLUNTARY PETITION
5~t;:i~
" ).. 0 1..:1 )
.., c..
,
•
:<~
- "
oJ •

~ U '" 15
.... ~ 00
~ O ·z U:!!
:s~c~
~ ~ ~ 16 1. Petitioners are the following: (a) Federal
Z 5i. ~<
0 ~ 17 Express Corporation, a corporation organized and existing under
Vl <
Z '"
0 lS the la~s of the state of Delaware; (b) Stanford University
g:!
t:.Q
19 Hospital; and (c~ The Board of Trustees of the Leland Stanford

20 Junior University {hereinafter collectively called the

21 "Petitioners ll } . Petitioners are creditors of Hamilton Taft &

22 Company, One Market Plaza, Spear street Tower, 32nd Floor, San

23 Francisco, California 94105 (hereinafter called the "Debtor").

24 Petitioners hold claims against the Debtor, not contingent as to

25 liability and not subject to bona fide dispute amounting to, in

26 the aggregate, in e~cess of the value of any lien held by them on

27 the Debtor's properties securing such claims, to at least

28

INVOLUNTARY PETITION
 $5,000.00.
-\..
-( !

The nature and amount of Petitioners' claims are as

2 follows:·
3 (a) Federal Express Corporation holds a claim
4 exceeding $32,000,000.00 for moneys advanced to Debtor, which
5 moneys should have been used for remission to the appropriate tax
6 authorities, but were not so used. On account of Debtor's

7 actions, in excess of $32,000,000.00 is owed by Debtor to Federal

B Express Corporation;
9 (b) Stanford university Hospital holds a claim
10 exceeding $1,700,000.00 for moneys advanced to Debtor, which
Z 11 moneys should have been used for remission to the appropriate ta~
0
Z
Z ... 12 authorities, but were not so used. On account of Debtor's
~ ~
u Iii ~ 13 actions, in excess of $1/700,000.00 is owed by Debtor to Stanford
~ ~
u.
o.:d
III
t;'" -z
~~ 1,4 University Hospital;
-.I
>- C
""
:l.l J
U.~
;:;: <II ~

;£.~c~
o u "" 15 (c) The Board of Trustees of The Leland Stanford
;to~~:!
j a: 90 16 Junior University holds a claim exceeding $296,000.00 for moneys ,/
ttl "" ~
:i ~ ~
0
oJl
Z
0
z.
""
."
17

18
advanced to Debtor, which moneys should have been used for·(Ur-"

remission to the appropriate tax authorities, but were not 50

A~lf,j ~ r\
~
c:O
19 used. On a ccount of Debtor' 5 a ct ions, in exce.ss of _$...4 96., 0 oq . 0 a -:> I
~,:w,.,!-~~-, _;';"!.JYr~/ J"-

20 is owed by Debtor to The Board of Trustees of The Leland Stanfo~

21 Junior University.

22 2. The Debtor1s principal place of business or

23 principal assets have been within this district for the 180 days

241 preceding the filing of this petition or for a longer portion of

25 the 180 days preceding the filing of this petition than in any

26 other district.
27 3. The Debtor is a person against whom an order for

28 relief may be entered under Title 11, United states Code.

INVOLUNTARY PETITION
2
 4. The Debtor is general not paying its debts which
:2 are not subject to bona dispute as they become due as
3 indicated by the Debts all 1 of this

petition are due, notwithstanding payment be

5 made , no payment has been promptly Debtor.
6 WHEREFORE I Pet that an order of reI be

7 ago. Debtor 11, Title 11, states

B Code.
9 RONSON & McKINNON
10

11
L H. AHR NS
12 Attorneys for Creditor
FEDERAL EXPRESS CORPORATION j

13 a Delaware corporation
Address:
14 505 Montgomery Street
san I CA 94111-2514
15
, DOYLE 1 BROWN &
16 ENERSEN
17
V)

z
o IB
e::!
CO
19 for STANFORD
HOSPITAL
20
Center
21 San 94111

22 , DOYLE, BROWN &

ENERSEN
23

26
Center
27 \M"A\99999\0900\PEflrl~.Pfl 94111
42tB-Wall&n
28

INVOLUNTARY PETITION
3
 VERIFICATION
2
I, ~a~i"C~I/.~A=~_Z_#~:~/I~~...:....I<?l........;~.;,.;..
.~.....;0"~__ , one of
3
the attorneys for the petitioner named in the forgoing
4
petition l declare under penalty of perjury that tbe
5
foregoing is true and correct according to the best of
6
my kno~ledge, information and belief.
7
Executed on March ~ , 1991.
8

10

Z 11
0 lone of
Z
Z
-
. 12
~ ~ the attorneys for the petitioner named in the forgoing
u t;; ~ 13
~ w <
'" -
~~t;~
petition, declare under penalty of perjury that the
." ~ e~
loa: - 'C"
lil
foregoing is true and correct according to the best of
~c w
~ :i
., 15
_oo~
::;O~b::S my knowledge, information and belief.
-' c::: C U 16
~ :< z
Executed on March >:60 , 1991.
i~~
0 :z 17
VI <
v-
Z
0 18
~
cQ
19

20 I I R~ ~ d , one of

21 the attorneys for the petitioner named in the forgoing

22 petition, declare under penalty of perjury that the

23 foregoing is true and correct according to the best of

24 my knowledge, information and belief.

25 Executed on March ~ 1991.

26

27

28

- -- - -- -- --- ----- - --_._ - -._._ --