19910320b Hamilton Taft Involuntary Petition

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MICHAEL H. AHRENS (state Bar No. 44766) GILMORE Y. DIEKMANN (state Bar No. 50400) LILLIAN G. STENFELDT (State Bar No. 104929) BRONSON, BRONSON & McKINNON 505 MontgoEery Street

San Francisco, california 94111-2514 Telephone:

(415) 996-4200

Attorneys for Petitioner FEDERAL EXPRESS CORPORATION, a Delaware corporation

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UNITED STATES BANKRUPTCY COURT

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NORTHERN DISTRICT OF CALIFORNIA

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Chapter 11

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INVOLUNTARY PETITION

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HAMILTON TAFT & COMPANY}

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In re a California corporation,

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Petitioners are the following:

(a)

Federal

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Express Corporation, a corporation organized and existing under

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Hospital; and (c~ The Board of Trustees of the Leland Stanford

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Junior University {hereinafter collectively called the

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"Petitioners ll } .

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

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

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Petitioners hold claims against the Debtor, not contingent as to

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

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the aggregate, in

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

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of the state of Delaware; (b)

Stanford University

Petitioners are creditors of Hamilton Taft &

e~cess

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INVOLUNTARY PETITION

of the value of any lien held by them on

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$5,000.00. 2

The nature and amount of Petitioners' claims are as

follows:·

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(a)

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Federal Express Corporation holds a claim

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exceeding $32,000,000.00 for moneys advanced to Debtor, which

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moneys should have been used for remission to the appropriate tax

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authorities, but were not so used.

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

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Express Corporation;

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(b)

On account of Debtor's

Stanford university Hospital holds a claim

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exceeding $1,700,000.00 for moneys advanced to Debtor, which

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moneys should have been used for remission to the appropriate

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authorities, but were not so used.

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actions, in excess of $1/700,000.00 is owed by Debtor to Stanford

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University Hospital;

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On account of Debtor's

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The Board of Trustees of The Leland Stanford

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Junior University holds a claim exceeding $296,000.00 for moneys ,/

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

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remission to the appropriate tax authorities, but were not

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used.

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On a ccount of Debtor' 5 a ct ions, in exce.ss of _$...4 96., 0 oq . 0 a -:> ~,:w,.,!-~~-,

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

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Junior University.

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2.

The Debtor1s principal place of business or

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principal assets have been within this district for the 180 days

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

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

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other district.

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3.

The Debtor is a person against whom an order for

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

INVOLUNTARY PETITION 2

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not paying its debts which

The Debtor is general

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are not subject to bona

dispute as they become due as

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indicated by the

Debts all

petition are due,

made , no payment has been promptly

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WHEREFORE I Pet

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ago.

payment be

notwithstanding

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1 of this

Debtor. that an order of reI

states

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Debtor

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Code.

RONSON & McKINNON

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Attorneys for Creditor

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a Delaware corporation Address: 505 Montgomery Street san I CA 94111-2514

FEDERAL EXPRESS CORPORATION

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, DOYLE 1 BROWN

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ENERSEN

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for STANFORD HOSPITAL

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San

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Center 94111 , DOYLE, BROWN &

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ENERSEN

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94111

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INVOLUNTARY PETITION 3

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VERIFICATION 2

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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

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kno~ledge,

information and belief.

Executed on March ~

, 1991.

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lone of

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the attorneys for the petitioner named in the forgoing

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foregoing is true and correct according to the best of

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petition, declare under penalty of perjury that the

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my knowledge, information and belief. Executed on March >:60

, 1991.

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, one of

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the attorneys for the petitioner named in the forgoing

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petition, declare under penalty of perjury that the

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foregoing is true and correct according to the best of

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my knowledge, information and belief. Executed on March ~

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1991.