Hanson is asking a federal court for an injunction against the $74-a-share leveraged buy-out offer from an investment group that was formed by Merrill Lynch and includes members of SCM top management. As in most leveraged buy-outs, most of the money for the deal will be raised by borrowing against the assets of SCM. The remainder constitutes equity paid by the buyers. In its lawsuit, Hansom claims that "the supposed 'equity' being provided by SCM management (and) Merrill Lynch . . . is in fact being provided out of the coffers of SCM by way of exorbitant giveaway fees to Merrill Lynch . . . and exorbitant and excessive benefits paid to management."