DONALD R BOYD 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 1 of 38
Donald R. Boyd 

4300 Lisa Lane 

Middletown, Ohio 45042 

October 21, 2003 

Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38197 

Re: Dalesandro, vs International Paper 

Case No. C-1-01-109 

US District Court, Southern District of Ohio 

Dear Ms Barger : 

In response to the court ordered Notice of September 24, 2003, we the individual members are to notify 

you in writing of discrepancies in the calculation of our severance pay and severance benefits of 

Severance Policy 828. 

My severance pay calculation is incorrect. Exhibit A to Class Notice, Donald R. Boyd, shows 11 .66 

years of service. My starting date with Champion International was September 3, 1985 . Therefore the 

correct number is 15.43 years of service, or 25.43 weeks of severance. At $1,402 .50 per week, my 

correct severance pay amount is $35,665.57. 

In addition, you left off other pertinent benefits that were part of the entire 828 package that I am 

eligible for, including vacation pay and 9 months of COBRA coverage . 

I am entitled to four (4) weeks of vacation pay at $1,402 .50 per week, for a total of $5,610.00. 

I am also entitled to nine (9) months of Cobra at ($95.63 medical & $25 .14 dental per pay) for 18 pay 

periods or $2,173 .86. 

This brings the total owed to me from International Paper to: 

Sincerely, 

Donald R. oS yy~ 

Cc: 

Murdock,Goldenberg,Schneider & Groh 

RECE1VE0 OCT 2 8 2003 

Salary $35,665.57 

Vacation $ 5,610.00 

Cobra $ 2,173.86 

Total $43,449.43 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 2 of 38
May 25, 2004 

Donald R. Boyd 

4300 Lisa Lane 

Middletown, Ohio 45042 

1NTERNAT"ONA PAPER 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Boyd, 

Cordially, 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

Isib 

Encl. 

CC: File 

International Place I 

6400 Poplar Ave. 

Memptvs, TN 38197 

Phone 901 763 6000 

We are in receipt of your letter dated October 21, 2003, in which you question the years of 

service used for the calculation of possible severance benefits payable under Champion 

International Corporation Reorganization Severance Policy #828 ("the Plan") as well as 

entitlement to vacation pay and reimbursement for COBRA coverage. The following will explain 

the results of our research. 

A review of your records indicates a previous period of Champion service should have been 

included in your estimated severance calculation . A corrected Exhibit A is enclosed. 

With regard to your request for vacation pay, when Smart Papers purchased the Hamilton Mill, 

the asset purchase agreement required Smart Papers to honor earned and accrued vacation for 

the employees it retained following the sale. Because you were retained by Smart Papers, 

Smart Papers was required to provide you with your earned and accrued vacation . 

With regard to your claim for COBRA benefits, all Hamilton Mill employees were provided with 

information related to their COBRA benefits at the time of the sale to Smart Papers. Under 

COBRA, continuation coverage must be elected within 60 days after your coverage ends or you 

are notified of your eligibility for continuation coverage, whichever is later. As the time for 

electing COBRA coverage has long past, you are no longer eligible for COBRA benefits. 

Furthermore, because you were hired by Smart Papers on or about February 9, 2001, you 

became eligible for Smart Paper's coverage which was comparable to the coverage provided by 

International Paper. When you obtained comparable coverage, you eligibility for COBRA 

ended. Thus, you are not currently eligible for COBRA benefits from International Paper. 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 3 of 38
Severance Calculation 

Age at 

February 9, 2001 

Weekly Pav Years of Service Termination Weeks of Severance 

$1402.50 16 44 32 

#828 Severance Pay: $44,880. 00 

Exhibit A 

Donald R Boyd 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 4 of 38
ARCH W.BRANDENBURG 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 5 of 38
October 10, 2003 

Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38197 

Re: Dalesandro, vs International Paper 

Case No. C-1-01-109 

US District Court, Southern District of Ohio 

Dear Ms Barger : 

In response to the court ordered Notice of September 24, 2003, we the individual 

members are to notify you in writing of discrepancies in the calculation of our severance 

pay and severance benefits of Severance Policy 828. 

You did indeed calculate my weeks of service and weekly pay correctly. That number 

46.38 weeks at $ 1,355.77 or $62,880.62, however you left off other pertinent benefits 

that were part of the entire 828 package that I am eligible for, that being vacation pay and 

9 months of COBRA coverage. 

Stir 

I am entitled to 4irae (6) weeks of vacation pay, $8,134 .62. 

Also 9 months of Cobra at ($95.63 medical & $25 .14 dental per pay) for 18 pay periods 

or $2,173 .86. 

This brings the total owed to me from International Paper to : 

Sincerely, 

yne Brandenburg 

Cc: 

MurdockGoldenberg,Schneider & Groh 

RECEIVED OCT 2 4 2003 

Salary $62,880.62 

Vacation $8,134 .62 

Cobra $2,173 .86 

Total $73,189.10 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 6 of 38
May 25, 2004 

Mr. Arch Wayne Brandenburg 

837 Oberlin Drive 

Fairfield, OH 45014 

INTERNATIONAL 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Brandenburg: 

Cordially, 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

International Place 1 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

We are in receipt of your letter dated 10124/2003, in which you question your entitlement to 

vacation and/or COBRA. The following will explain the results of our research. 

With regard to your request for vacation pay, when Smart Papers purchased the Hamilton Mill, 

the asset purchase agreement required Smart Papers to honor earned and accrued vacation for 

the employees it retained following the sale. Because you were retained by Smart Papers, 

Smart Papers was required to provide you with your earned and accrued vacation . 

With regard to your claim for COBRA benefits, all Hamilton Mill employees were provided with 

information related to their COBRA benefits at the time of the sale to Smart Papers. Under 

COBRA, continuation coverage must be elected within 60 days after your coverage ends or you 

are notified of your eligibility for continuation coverage, whichever is later. As the time for 

electing COBRA coverage has long past, you are no longer eligible for COBRA benefits . 

Furthermore, because you were hired by Smart Papers on or about February 9, 2001, you 

became eligible for Smart Paper's coverage which was comparable to the coverage provided by 

International Paper. When you obtained comparable coverage, you eligibility for COBRA 

ended. Thus, you are not currently eligible for COBRA benefits from International Paper. 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 7 of 38
DAVID BRISEBOIS 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 8 of 38
October 8, 2003 

Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38197 

Re: Dalesandro, vs International Paper 

Case No. C-1-01-109 

US District Court, Southern District of Ohio 

Dear Ms Barger: 

In response to the court ordered Notice of September 24, 2003, we the individual 

members are to notify you in writing of discrepancies in the calculation of our severance 

pay and severance benefits of Severance Policy 828. 

You did indeed calculate my weeks of service and weekly pay correctly. That number 

11.20 weeks at $1,438.47 or $16,110.87, however you left off other pertinent benefits 

that ,we part, of the pntue 828, package that I am eligible for, drat being vacation pay and 

4 months of COBRA coveiage. 

I am entitled to three (3) weeks of vacation pay, $4,315 .41 . 

Also 9 

or $2,173 .86. 

of Cobra at ($95.63 medical & $25.14 dental per pay) for 18 pay periods 

This brings the total owed to me from International Paper to : 

Sincerely, 

vid Brisebois 

RECEIVED OCT 2 4 2003 

Salary $16,110.87 

Vacation $4,315 .41 

Cobra $2,173 .86 

Total. $22,600.14 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 9 of 38
May 25, 2004 

Mr. David Brisebois 

34 Iroquois Ave. 

Hubbardston, MA 01452 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Brisebois: 

INTERNATIONAL PAPER 

International Place I 

6400 Poplar Ave. 

Memphis, TN 36197 

Phone 901 763 6000 

We are in receipt of your letter dated 1012412003, in which you question your entitlement to 

vacation and/or COBRA. The following will explain the results of our research. 

With regard to your request for vacation pay, when Smart Papers purchased the Hamilton Mill, 

the asset purchase agreement required Smart Papers to honor earned and accrued vacation for 

the employees it retained following the sale. Because you were retained by Smart Papers, 

Smart Papers was required to provide you with your earned and accrued vacation. 

With regard to your claim for COBRA benefits, all Hamilton Mill employees were provided with 

information related to their COBRA benefits at the time of the sale to Smart Papers. Under 

COBRA, continuation coverage must be elected within 60 days after your coverage ends or you 

are noted of your eligibility for continuation coverage, whichever is later. As the time for 

electing COBRA coverage has long past, you are no longer eligible for COBRA benefits . 

Furthermore, because you were hired by Smart Papers on or about February 9, 2001, you 

became eligible for Smart Paper's coverage which was comparable to the coverage provided by 

International Paper. When you obtained comparable coverage, you eligibility for COBRA 

ended . Thus, you are not currently eligible for COBRA benefits from International Paper. 

Cordially, 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 10 of 38
DEBORAH BROCKMAN-JESTER 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 11 of 38
October 15, 2003 

Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38197 

Re: Dalesandro, vs. International Paper 

Case No. C-1-01-109 

US District Court, Southern District of Ohio 

Dear Ms. Barger. 

In response to the court ordered Notice of September 24, 2003, we the individual members are to notify 

you in writing of discrepancies in the calculation of our severance pay and severance benefits of Severance 

Policy #828. 

You did indeed calculate my weeks of service and weekly pay correctly. That number 22.56 weeks at 

$ 647.12 or $ 14,599.03, however you left off other pertinent benefits that were part of the entire 828 

package that I am eligible for, that being vacation pay and 9 months of COBRA coverage. 

I am entitled to three (3) weeks of vacation pay, $1,941 .36. 

Also, 9 months of COBRA at ($95 .63 medical_ and $25 .14 dental per pay) for 18 pay periods or $2,173 .86. 

This brings the total owed to me from International Paper to : 

Salary $14,599.03 

vacation $ 1,941 .36 

COBRA $ 2,173.86 

Total $18,714.25 

Deborah Brockman-Jester 

2474 Stahlheber Road (new address) 

Hamilton, OH 45013 

Cc: 

Murdock, Goldenberg, Schneider & Groh 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 12 of 38
May 25, 2004 

Ms. Deborah K. Brockman-Jester 

74 Winston Drive 

Hamilton, OH 45013 

Dear Ms. Brockman-Jester: 

Cordially, 

INTERNATIONAL 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

PAPER 

Re: Champion International Corporation Reorganization Severance Policy #828 

International Place 1 

6400 Poplar Ave. 

Memphis, TN 36197 

Phone 901 763 6000 

We are in receipt of your letter dated 10/2012003, in which you question your entitlement to 

vacation and/or COBRA. The following will explain the results of our research. 

With regard to your request for vacation pay, when Smart Papers purchased the Hamilton Mill, 

the asset purchase agreement required Smart Papers to honor earned and accrued vacation for 

the employees it retained following the sale. Because you were retained by Smart Papers, 

Smart Papers was required to provide you with your earned and accrued vacation. 

With regard to your claim for COBRA benefits, all Hamilton Mill employees were provided with 

information related to their COBRA benefits at the time of the sale to Smart Papers. Under 

COBRA, continuation coverage must be elected within 60 days after your coverage ends or you 

are notified of your eligibility for continuation coverage, whichever is later. As the time for 

electing COBRA coverage has long past, you are no longer eligible for COBRA benefits . 

Furthermore, because you were hired by Smart Papers on or about February 9, 2001, you 

became eligible for Smart Paper's coverage which was comparable to the coverage provided by 

International Paper. When you obtained comparable coverage, you eligibility for COBRA 

ended. Thus, you are not currently eligible for COBRA benefits from International Paper. 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 13 of 38
RALEIGH BRUCE, JR. 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 14 of 38
RALEIGH BRUCE JR. 

September 25, 2003 

Sharon Barger 

International Paper 

6400 Poplar Ave 

Memphis, Tennessee 38197 

Dear Sharon, The severance pay calculation under policy #828 that you made was in error. My 

start date at Champion International was August 1983 . During that time frame I moved from 

hourly to a salary position and retained all years of service that I previously earned My 

retirement benefits also were shifted to salary . My years of service should be 18.5 years. 

Sincerely, 

Raleigh Bruce Jr . 

RECEIVED SEP 3 0 2003 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 15 of 38
Age at 

Febnrary 9,2101 

Weekly Pay Years of Service Termination Weeks of Severance 

$757.70 3.08 52 13.08 

Exhibit A to Class Notice 

Raleigh Bruce, Jr. 

YOUR SEVERANCE PAY CALCULATION UNDER POLICY #828 

Your #828 Severance Pay Amount: $9,910.72 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 16 of 38
September 16, 2004 

Raleigh Bruce 

241 N Brookwood Avenue 

Hamilton, Ohio 45013 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Bruce, 

We are in receipt of your letter dated September 25, 2003, in which you question the years of 

service used for the calculation of possible severance benefits payable under Champion 

International Corporation Reorganization Severance Policy #828 ("the Plan"). 

A review of your records indicates a previous period of Champion service should have been 

included in your estimated severance calculation as well as your eligibility for the pension 

enhancement. A corrected Exhibit A is enclosed along with updated pension information . 

Cordially, 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

/sib 

Encl . 

CC : File 

International Place I 

6400 Poplar Ave. 

Memphis, TN 38187 

Phone 901 763 6000 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 17 of 38
09/ 0 7/04 

ESTIMATED 

SEVERANCE PLAN STATEMENT 

POLICY 828 

RALEIGH BRUCE JR 

PERM PAPERS MILL OF 

002HAOH 

IP SEVERANCE WEEKS : 36 .00 

IF SEVERANCE PAY : $27,277 .20 

THIS ESTIMATE WAS BASED ON THE DEMOGRAPHIC INFORMATION 

ASOVE AND THE WEEKS OF SEVERANCE WERE BASED ON YOUR LAST 

DATE OF HIRE WITH THE COMPANY . IF YOU HAVE ADDITONAL 

SERVICE THAT MAY BE USED IN THE SEVERANCE CALCULATION, 

PLEASE SEE YOUR HUMAN RESOURCES REPRESENTATIVE 

HIRE DATE : 09/23/83 

TERMINATION DATE : 02/09/01 

WEEKLY PAY : $757 .70 

YEARS OF SERVICE : 17 .38 

WEEKS OF SEVERANCE : 29 .76 

SEVERANCE PAY: $22,549 .16 

OR, IF GREATER, 

IV YEARS OF SERVICE : 18 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 18 of 38
Flex6 Calculation for Raleigh Bruce Jr 

Social Security Number

Employee Data 

Social Security Number: 

Name: Raleigh Bruce Jr 

Date of Birth : 

Date of Hire : 08/24/1983 

Marital Status: S 

Spouse's Date of Birth

Last Date of Hire: 01/12/1998 

Location Code: 002HAOH 

Current Annual Base Pay Amount: $39,400.08 

Date of Termination: 02/09/2001 

Credited Service: 17 .15000 

Vesting Service: 17 .38000 

Monthly Final Average Pay: $3,351 .52 

Current Monthly Social Security: $1,462.00 

Flex 6 Monthly Social Security : $1,181 .00 

Age 62 Monthly SS for Level Income: $1,181 .00 

Age 65 Monthly SS for Level Income: $1,462 .00 

Processing Notes 

Prepared By: swp 09/07/2004 

WARNING: Check service entries. Credited Service and Vesting Service differ by at least 0.1 years. 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 19 of 38
SINGLE LIFE ANNUITY - You will receive a payment for your lifetime, 

payments stop at your death. 

50% CONTINGENT ANNUITANT/JOINT & SURVIVING SPOUSE 

75% CONTINGENT ANNUITANT/JOINT & SURVIVING SPOUSE 

100% CONTINGENT ANNUTTANTIJOINT & SURVIVING SPOUSE 

$503.52 5 YEAR CERTAIN 

5377.83 10 YEAR CERTAIN 

$447.01 15 YEAR CERTAIN 

$416.18 20 YEAR CERTAIN 

CONTINGENT ANNUITANT ANNUITY OPTIONS - You will receive a monthly 

benefit during your lifetime and guarantee that the contingent 

annuitant you designate will receive a selected percentage of that 

benefit for their lifetime after your death . 

LIFE-TERM CERTAIN ANNUITY OPTIONS - This option provides you with a 

monthly benefit for your lifetime . If you die within the selected 

guaranteed period, your named beneficiary will continue to receive 

the same monthly amount for the balance of the period. If you live 

longer than the guaranteed period, payments stop at your death. 

$867.85 to 03/01/2010 LEVEL INCOME OPTION -This option pays a larger benefit to age 62 

and a benefit after age 62, reduced to account for social security . 

$0.00 thereafter Payments stop at your death . 

$724.95 to 03/012013 LEVEL INCOME OPTION -This option pays a larger benefit to age 65 

and a benefit after age 65, reduced to account for social security . 

$0.00 thereafter Payments stop u your death . 

$472.70 FULL CASH REFUND ANNUITY -This option provides you with a monthly 

benefit for lifetime with a guarantee that if you die before 

receiving payments equal m the total annuity value, your named 

ANNUITY VALUE beneficiary will receive the difference in a lump sum. If you die 

$66,876 .21 after the monthly payments exceed the annuity value, payments stop 

at your death. 

I you are not married, the single life annuity is the basic form of retirement benefit under the plan. 

If you are married, the joint & surviving spouse annuity is the basic form of retirement 

benefit under the plan and is payable in the amounts shown under the 50% contingent an 

option above. 

To retiree To Contingent 

Annuitant 

$513.80 N/A 

N/A N/A 

N/A N/A 

N/A N/A 

SALARIED RETIREMENT 

OPTIONAL FORMS 

PLAN 

OF RETIREMENT BENEFITS 

Name: Raleigh Bruce Jr Plan Number: 001A 

Social Security Number : Retirement Date: 03/01/2001 

Date Prepared: 09/07/2004 

Monthly Benefit Payable 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 20 of 38
SCHEDULE OF DEATH BENEFIT AFTER RETIREMENT 

DEATH BENEFITS AFTER RETIREMENT 

Amount From To 

$5,000 .00 03/01/2001 Thereafter 

Name Raleigh Bruce It Retirement Date 0310112001 

Social Security Number Hire Date 08/24/1983 

Plan Number OOIA Birth Date 

Date Prepared 09107/2004 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 21 of 38
JOEL BRYANT 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 22 of 38
October 13, 2003 

Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38197 

Re: Dalesandro, vs International Paper 

Case No. C-1-01-109 

US District Court, Southern District of Ohio 

Dear Ms Barger : 

In response to the court ordered Notice of September 24, 2003, we the individual 

members are to notify you in writing of discrepancies in the calculation of our severance 

pay and severance benefits of Severance Policy 828. 

You did indeed calculate my weeks of service and weekly pay correctly. That number 

46.20 weeks at $ 1,225.00 or $56,595.00, however you left off other pertinent benefits 

that were part of the entire 828 package that I am eligible for, that being vacation pay and 

9 months of COBRA coverage . 

I am entitled to three (6) weeks of vacation pay, $7,350 .00. 

Also 9 months of Cobra at ($198.94 medical & $21 .00 dental per pay) for 18 pay periods 

or $3958.92. 

This brings the total owed to me from International Paper to : 

Sincerely, 

Joel Bryant 

1764 T hall Drive 

Hamilton,Ohio 45013 

Cc: 

Murdock,Goldenberg,Schneider &- Groh 

RECEIVED OCT 1 6 M 

Salary $56,595.00 

Vacation $ 7350.00 

Cobra $ 3958.92 

Total $67903.92 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 23 of 38
May 25, 2004 

Mr. Joel E. Bryant 

1764 Thall Drive 

Hamilton, OH 45011 

Dear Mr. Bryant: 

Cordially, 

INTERNATIONAL 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

Re: Champion International Corporation Reorganization Severance Policy #828 

international Place 1 

6400 Poplar Ave. 

Memphis, TN 38197 

Plane 901 763 6000 

We are in receipt of your letter dated 10/16/2003, in which you question your entitlement to 

vacation and/or COBRA. The following will explain the results of our research. 

With regard to your request for vacation pay, when Smart Papers purchased the Hamilton Mill, 

the asset purchase agreement required Smart Papers to honor earned and accrued vacation for 

the employees it retained following the sale. Because you were retained by Smart Papers, 

Smart Papers was required to provide you with your earned and accrued vacation . 

With regard to your claim for COBRA benefits, ail Hamilton Mill employees were provided with 

information related to their COBRA benefits at the time of the sale to Smart Papers. Under 

COBRA, continuation coverage must be elected within 60 days after your coverage ends or you 

are notified of your eligibility for continuation coverage, whichever is later. As the time for 

electing COBRA coverage has long past, you are no longer eligible for COBRA benefits . 

Furthermore, because you were hired by Smart Papers on or about February 9, 2001, you 

became eligible for Smart Paper's coverage which was comparable to the coverage provided by 

International Paper. When you obtained comparable coverage, you eligibility for COBRA 

ended. Thus, you are not currently eligible for COBRA benefits from International Paper. 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 24 of 38
BOB BUCHANAN 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 25 of 38
October 12, 2003 

Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38197 

Re: Dalesandro, vs International Paper 

Case No. C-1-01-109 

US District Court, Southern District of Ohio 

Dear Ms Barger: 

In response to the court ordered Notice of September 24, 2003, we the individual 

members are to notify you in writing of discrepancies in the calculation of our severance 

pay and severance benefits of Severance Policy 828. 

However you left off other pertinent benefits that were part of the entire 828 package 

that I am eligible for, that being vacation pay and COBRA coverage . 

I am entitled to four (4) weeks of vacation pay, also cobra. 

Sincerely, 

BOB BUCHANAN 

Cc: 

Murdock,Goldenberg,Schneider & Groh 

RECEIVED OCT 2 r M 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 26 of 38
Cordially, 

INTERNATIONA 

May 25, 2004 

Mr. Bob Buchanan 

P.O. Box 206 

Hamilton, OH 45012 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Buchanan: 

We are in receipt of your letter dated 10/20/2003, in which you question your entitlement to 

vacation and/or COBRA. The following will explain the results of our research. 

With regard to your request for vacation pay, when Smart Papers purchased the Hamilton Mill, 

the asset purchase agreement required Smart Papers to honor earned and accrued vacation for 

the employees it retained following the sale. Because you were retained by Smart Papers, 

Smart Papers was required to provide you with your earned and accrued vacation. 

With regard to your claim for COBRA benefits, all Hamilton Mill employees were provided with 

information related to their COBRA benefits at the time of the sale to Smart Papers. Under 

COBRA, continuation coverage must be elected within 60 days after your coverage ends or you 

are notified of your eligibility for continuation coverage, whichever is later. As the time for 

electing COBRA coverage has long past, you are no longer eligible for COBRA benefits . 

Furthermore, because you were hired by Smart Papers on or about February 9, 2001, you 

became eligible for Smart Paper's coverage which was comparable to the coverage provided by 

International Paper. When you obtained comparable coverage, you eligibility for COBRA 

ended. Thus, you are not currently eligible for COBRA benefits from International Paper. 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

PAPER 

International Place I 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 27 of 38
CHERYL A. BUNN 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 28 of 38
October 24, 2003 

Sharon Bang 

Intanational Papa 

6400 Poplar Avenue 

MempW Tenneaaee 38197 

Re: Datesaodro, vs International Papa 

Can No. C" 1-01_109 

US District Court, Southern District of Oleo 

Dew Ms Barge: 

In response to the court ordered Notice of September 24, 2003, we the individual 

members are to notify you in writing of discrepancies is the ululation Four severance 

pay and severance beoafits of Severance Policy 823. 

You did indeed calculate my weeks of service and weedy pay correctly. That number 

30.82 wears at 5965.39 per wedr, or $29,753 .32 . Howwa, you left off other patinent 

bereft that were put of the entire 828 package that I am eligible for, that being vacation 

pay and 9 moat6e ofCOBRA coverage. 

I on endow to five (5) wears of vacation pay, $4,826.95. 

Also, 9 months of COBRA at ($95.63 me" & $25.14 denial per pay) for 18 pay periods 

or $2,173.86. 

This brings the tad owed to me from international Paper to: 

Cheryl A.1 

d Groh 

RECEIVED OCT 2 8 2003 

Salary $29,753 .32 

Vacs 4,326.95 

COBRA 2,173.86 

Total 536,754.13 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 29 of 38
May 25, 2004 

Ms. Cheryl A. Bunn 

324 Mollie Drive 

Hamilton, OH 45013 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Ms. Bunn: 

INTERNATIONAL PAPER 

Intema6onal Place I 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

We are in receipt of your letter dated 10128/2003, in which you question your entitlement to 

vacation and/or COBRA. The following will explain the results of our research. 

With regard to your request for vacation pay, when Smart Papers purchased the Hamilton Mill, 

the asset purchase agreement required Smart Papers to honor earned and accrued vacation for 

the employees it retained following the sale. Because you were retained by Smart Papers, 

Smart Papers was required to provide you with your earned and accrued vacation. 

With regard to your claim for COBRA benefits, all Hamilton Mill employees were provided with 

information related to their COBRA benefits at the time of the sale to Smart Papers. Under 

COBRA, continuation coverage must be elected within 60 days after your coverage ends or you 

are notified of your eligibility for continuation coverage, whichever is later. As the time for 

electing COBRA coverage has long past, you are no longer eligible for COBRA benefits . 

Furthermore, because you were hired by Smart Papers on or about February 9, 2001, you 

became eligible for Smart Paper's coverage which was comparable to the coverage provided by 

International Paper. When you obtained comparable coverage, you eligibility for COBRA 

ended. Thus, you are not currently eligible for COBRA benefits from International Paper. 

Cordially, 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 30 of 38
BRENDA GAIL BURNS 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 31 of 38
Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38197 

25, 2003 

Regarding my severance pay calculation in Exhibit A, I am writing to disagree with the 

years of service calculation, and the weeks of severance. 

I have enclosed copies of previous salary review notices that will help explain my 

situation. First of all, my original hire date with Champion International was 4-1-74, and 

I worked until 10-82 to be a full time Mom for a short time. Then I was rehired back 

with Champion International on 1-23-89 at which time I was given credit for my previous 

years of employment with an adjusted hire date of 6-7-80. At no time was I ever given a 

severance package from Champion International. My previous years of employment 

were recognized. When rehired on 1-23-891 did not "start over" with the company, but 

was allowed for my previous time of employment and service to continue. I feel I should 

get credit for 21 years of service and 37 weeks of severance. 

Therefore, I feel the following calculations are correct using $688.47 weekly pay: 

yam. ' 

Regarding Section 7 Miscellaneous Benefits 7.1 Vacation Pay: At the time of severance 

on February 9, 20011 was entitled to 5 weeks of vacation earned in the previous year, 

which due to my adjusted hire date of 6-7-80, would total $3,442 .35. 

Thank you for your time and consideration in this matter. 

Gail Burns 

1910 Amarillo Drive 

Hamilton, Ohio 45013 

37 weeks a $688.47 = $25,473.39 

RECEIVED 5EP 3 0 2003 

a) ten (10) weeks earnings plus: 

b) one (1) week (or partial weeks) earnings for each year 

(10 weeks) 

(21 weeks) 

$6,884.70 

$14,457.87 

of credited service plus : 

c) one (1) week (or partial weeks) earnings for each (6 weeks) $4,130.82 

year (or partial year) of credited service over (15) 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 32 of 38
Current Information 

PRINTING E WRITING PAPERS MFG HAMILTON UH 

Posifionf SalaryfGradelSchedulel Range 

Position Title Grade Schedule Range: Minimum 

__ SST ORVM REPT 65 6 - 

Annual ' S/M Rate Hrty Rate AdIgM Grade Schedule Range: Minimum Midpoint 

18, 250, $ 76t1~42 ~ 8 .7740 

ation (Complete Applicable Change Data Only) 

1. Review Dale Effective Date -Change Amour,, 

920716 1 901016 $ -700-00 

x~ ~a :- .  fi.;.~r, ~ :Pievlous rSalary.Change Aan, - , ,' 

trop 

- 

Effective Date Change Amour 

1 1 900116 $ 900.=00 

Annual . 19,450.00 

1,200.00 1 6 .57 % I 

Position Change 

Posmon Tine 

t 

C. Business UnRIDepartmentlLocation Change 

New Business Unit Name 

D. Sep LOAILAYOFF 

Approvals 

Initialed By. 

as UnitIDepartmentlLocation 

mess Unit Name Business Unit Location 

Mae Hacker 

,- Approved By: 

Status Term. Reason and Code 

Unused Vacakon 

, days 

Remarks and Other Changes 

LDdd Downev 

nil Champion 

2 Position Change . 

Date 

Date 

Term Retire Date Retirement Status Death Date 

mination'Retirement 5 Leave of Absence 6.f{ie 

nt 

e Pay Deferred Vacation 

wksI wks i 

in ment - 

Prior go' e Prior Term . Date Reason 

J S 

740401 821116 ° Ov 

L3 L4 1 .5lHome Dept .) L6 

PMHA .5430 8420 5430 -PMHA, 

ai iA Midpoint Maximum Pay Code Pay Fre FPPT Std. HM.,-k~ 

5 N 35 'IER'- '86,6611 

um EEO Cal, Pos. Na Next Set. Revew Data . 

05 842000151" 921016 ,su` 

7. Re-Hue 

Hamil n il 

Last Day Waked LOAILO Type LOAfw Begin LOAILD .End 

After Final Approval Return Tb"" ,. " '- 

Date w 

Mae Hacker 

State Zip t 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 33 of 38
Initi 

Appro 

Approved 

(yj Conelstanty exceeding expectailons, surpassing established goals, and regulery 

making RAreordinary oomributbns to the company . 

( ) Fully sldlled and knowledgeable In ail areas of responsibility, and consistently 

meeting the principal job obbctNee gfr a sustained perbd of time . 

( ) Acquiring the necessary xMils and leaning essential job elements. 

NOT meeting rformanca loos 

ate of Approval e um o: 

Date 

Date 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 34 of 38
Vacaton Eligibility Date' . 

!nitiWed . 8y'.' .` - 

Approved By 

s 

Approved By : 

FGFS(liifa 

21,542 - 24,415 - 27,287 - 30,-159 

Date Approved By: 

Date / Q ~ 3 6 i 9. 

-Approved By 

Date .. / t Approved By : 

unampioq 

pion Intemational C 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 35 of 38
tionr':! a4*,' 

002H,AOH . HAHT4 

. :F.' hd .u=t n} 

f ReestnlDescriplion "? 

"; .SALARY-:Jk 

Date 

Dale // S' 

Date 

)proved . 

Approved 

Approved 

sgafe' ' 

d147, 

fendardHours ' . 

` .$6.66 

Salary Action/DawflotiOn 

pSum% Flex Benefits Earnings 

) ~ aimed Performance Level (Choose one "X") 

,{tkonsist¢nily exceeding expectations, surpassing established goals, and regularly making extraordinary 

contributions' to the company: 

skilled and knowledgeable In all areas of responsibility, and consistently meeting . the principal 

b/ecilves for a sustained period of time. 

Acquiring the necessary skills and learning essential job elements. 

NOT meeting performance expecteions . 

Sfandafdllour 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 36 of 38
May 25, 2004 

Brenda G. Burns 

1910 Amarillo Drive 

Hamilton, Otmo 45013 

Dear Ms. Bums, 

Cordially, 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

/sib 

Encl. 

CC: File 

INTERNATIONA 

Re: Champion International Corporation Reorganization Severance Policy #828 

International Place I 

6400 Poplar Ave. 

MempNs, TN 38197 

Phone 901 763 6000 

We are in receipt of your letter dated September 25, 2003, in which you question the years of 

service used for the calculation of possible severance benefits payable under Champion 

International Corporation Reorganization Severance Policy #828 ("the Plan") as well as 

entitlement to vacation pay. The following will explain the results of our research. 

A review of your records indicates a previous period of Champion service should have been 

included in your estimated severance calculation . A corrected Exhibit A is enclosed. 

In your letter, you also question your entitlement to vacation pay. When Smart Papers 

purchased the Hamilton Mill, the asset purchase agreement required Smart Papers to honor 

earned and accrued vacation for the employees it retained following the sale. Because you 

were retained by Smart Papers, Smart Papers was required to provide you with your earned 

and accrued vacation. 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 37 of 38
Severance Calculation 

Age at 

February 9, 2001 

Weekly Pav Years of Service Termination Weeks of Severance 

$688.47 21 45 42 

#828 Severance Pay: $28,915.74 

Exhibit A 

Brenda Barns 

Case 1:01-cv-00109-SSB Document 73-6 Filed 09/17/2004 Page 38 of 38