George and Kathleen Knevelbaard, et al. - Page 3

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                  Petitioners are dairy farmers (milk producers) who sold raw                         
            milk to Knudsen Dairy (Knudsen), a large independent processor                            
            and distributor of dairy products in California.  The                                     
            Knevelbaards are members of the South Valley Milk Producers                               
            Cooperative, and the Christians are members of the Cal-Dari                               
            Cooperative.  Petitioners Gomes, Kooistra, and Brown are                                  
            independent producers.  The Souzas are partners in P&L Souza                              
            Dairy.                                                                                    
                  In early 1985 Knudsen purchased Foremost Dairies (Foremost).                        
            Citicorp Industrial Credit, Inc. (Citicorp), along with Security                          
            Pacific Business Credit, Inc., Wells Fargo Business Credit, Inc.,                         
            Goldome Bank, and National Bank of Canada, provided the financing                         
            for Knudsen’s purchase of Foremost (collectively, Bank                                    
            Defendants).  As part of the financing agreement for Knudsen’s                            
            purchase of Foremost, the Bank Defendants also refinanced                                 
            Knudsen's existing debt.                                                                  
                  Knudsen entered into long-term agreements with dairy farm                           
            cooperatives and independent producers, including petitioners,                            
            for the purchase of raw milk.  The contracts required Knudsen to                          
            buy all milk produced by the milk producers.  Knudsen was                                 












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