SPENCER M. ADSIT 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 1 of 43
Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38197 

Re: Datesandro, vs International Paper 

Case No. C-1-01-109 

US District Court, Southern District of Ohio 

4450 Oxford Trenton Rd. 

Oxford, OH 45056 

October 8, 2003 

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 0 .98 weeks at $1,442.31 or $15,836.57, however I believe you left off other 

pertinent benefits that were part of the entire 829 package that I am eligible for, that 

being vacation pay and 9 months of COBRA coverage. 

I believe I am entity to three (3) weeks of vacation pay, totaling $4,326 .93. 

Also, I believe I am entitled to the value of 9 months of Cobra at ($95.63 medical 

& $25.14 dental per pay) for 18 pay periods or $2,173 .86. Please excuse me if I am in 

error on this amount, as I no longer have all those old medical records. 

This should bring the total owed to me by International Paper to: 

Murdock,Goldenberg,Schneider & Groh 

RECEIVED OCT 2 3 2003 

Salary $15,836.57 

Vacation $4,326 .93 

Cobra $2 173 86 

Total $22,337.36 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 2 of 43
June 16, 2004 

Mr. Spencer M. Adsit 

4450 Oxford Trenton Road 

Oxford, OH 45056 

Dear Mr. Adsit: 

Cordially, 

INTERNATIONAL 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

Re: Champion International Corporation Reorganization Severance Policy #828 

International Place I 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

We are in receipt of your letter dated 10/23/2003, 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 73-5 Filed 09/17/2004 Page 3 of 43
RICHARD AHNER 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 4 of 43
October 10, 2Q03 

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 

14.10 weeks at $1,232 .70 or $17,381 .07, 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 (4) weeks of vacation pay, $4,930 .80. 

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: 

Richard 

12025 Bridgeport Lane 

Springdale,'IIhio 45240 

Murdock,Goldenberg,Schneider & Groh 

RECEIVED OrT 7 0 2003 

Salary $17,381 .07 

Vacation $4,930.80 

Cobra $2,173 .86 

Total $24,485.73 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 5 of 43
May 25, 2004 

Mr. Richard J. Ahner 

12025 Bridgeport Lane 

Springdale, OH 45240 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Ahner: 

INTERNATIONAL 

Intemabonal Place 1 

6400 Poplar Ave. 

mampNs,TN 38197 

Phone 901 763 6999 

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 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 73-5 Filed 09/17/2004 Page 6 of 43
MIKE J. ALLEN 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 7 of 43
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 His 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 Pofcy 828. 

You did i calculate my weeks of service and 

46.26 weeks at 1,361 .54, however you Left off other 

the entire 828 package that I am eligible for, that being 

COBRA coverage. 

pay correctly. That number 

benefits that were part of 

and 9 months of 

I am entitled to eight (8) weeks of vacation pay at 10, 892.32. I have two extra weeks of 

vacation that I did not take. I have set you the letter from An neetta Johnson explaining 

why. 

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: 

Salary $62,984.85 

Vacation $10,892.32 

Cobra $2,173.86 

Total $76,051 .03 

Mince Allen 

Cc: 

1* WEm 

Goldenberg, Schneider & Groh 

RECEIVED or,T ' 6 2003 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 8 of 43
May 25, 2004 

Mr. Mike J. Alien 

6009 Wayne Trace Rd. 

Somerville, OH 45064 

INTERNATIONAL 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Allen: 

PAPER 

Intemationai Place 1 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901763 6009 

We are in receipt of your letter dated 10/1612003, 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 73-5 Filed 09/17/2004 Page 9 of 43
Away 11, LVU1 

I have two weeks vacation remaining from the you 2400. 1 was told by Annetta Johnson 

that I have until April I, 2001 to take my two remaining weeks of vacation that is k8 

over from 2400. I was informed by Annetta Johnson that if I am not employed with - 

Smart Papas that I will be paid for the two weeks vacation remaining from 2000. 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 10 of 43
SHARON N. ALLEN 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 11 of 43
October 15, 2003 

Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38197 

Re: Dalesandro, vs. International Paper 

Case No. GI-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 30.72 weeks at 

$ 650.47 or $ 19,997.80, 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 five (5) weeks of vacation pay, $3,254 .85 . 

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 the from International Paper to: 

Sincerely, 

Sharon Allen 

Cc: 

Murdock, Goldenberg, Schneider & Groh 

Salary $19,997.80 

Vacation $ 3,254.85 

COBRA $ 2,173.86 

Total $25,426.51 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 12 of 43
May 25, 2004 

Ms . Sharon N. Alien 

5297 Layhigh Road 

Hamilton, OH 45013 

Dear Ms. Allen: 

Cordially, 

INTERNATION 

Re: Champion International Corporation Reorganization Severance Policy #828 

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 80 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. 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

PAPER 

International Place 1 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 783 8000 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 13 of 43
BRETT ANDROSKI 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 14 of 43
May 25, 2004 

Mr. Brett Androski 

9045 Shadetree Drive 

Cincinnati, OH 45242 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Androski: 

We are in receipt of your letter dated 10/14/2003, 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 mart 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 80 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, 

INTERNATIONAL 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

PAPER 

International Place 1 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 15 of 43
October 10, 2003 

Sharon Berg 

International Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38197 

Re: Dalesandro, vs International Paper 

Case No. C-1-01-109 

US Distrct 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. This letter is my communication that my benefits have not 

been completely accounted for in my Exhibit A to Class Notice, Severance Pay Calculation Under 

Policy #826. 

ou did calculate my weeks of service and weekly pay correctly. That number is 19.92 weeks at 

1,476.93 per week or $29,420.45. You did not account for other pertinent bents that were 

; of the entire 828 package that I am eligible for, that being vacation pay and COBRA 

e. 

entitled to three (3) weeks of vacation pay at $1,476.93 per week or $4,430.79. 

also entitled to nine months Cobra coverage which amounted to $504.90 in costs to me. 

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

Sincerely, 

Brat Androski 

Murdock,Goldenberg,Schneider & Groh 

Bret Androski 

9045 Shadetree Dr. 

Cincinnati, OH 45242 

(513) 791-9048 

Scary $29,420.45 

Vacation $4,430.79 

Cobra $504.90 

Total $34,356.14 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 16 of 43
ANDREA ANGST 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 17 of 43
Cordially, 

INTERNATIONAL 

May 25, 2004 

Ms. Andrea Angst 

611 Leo Drive 

Hamilton, OH 45013 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Ms . Angst: 

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 far 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, an 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. 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

PAPER 

Intemational Place i 

6400 Pour Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 18 of 43
October 10,2003 

Shares Barger 

international Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38197 

Re: Angst, vs. International Paper 

Cast No. C-1-01-109 

us District Court, Southern District of Ohio 

Dear Ms Bargee. 

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

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

of Severance Policy 828. 

You did calculate my weeks of service and weekly pay correctly. The calculation of 27.38 weeks at 

$598.08, or a total of S16,375.44 is correct. However, you left off other pertinent benefits that were 

part of the entire 828 package that I am eligible for. I am also entitled to 4 weeks vacation pay. That 

would calculate oat to 4 weeks X SS98.08, or 52,392.32. 

The total owed to me would be: 

Severance pay amount $16,375.44 

Vacation pay 92.32 

TOTAL S18,767.76 

Sincerely, 

Andrea E. Angst 

Ce: Murdoch, Goldenberg, Schneider & Grob 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 19 of 43
DANIELLE BALES 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 20 of 43
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 

12.10 weeks at $ 527.89 or $6,387 .47, however you left off other pertinent benefits that 

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

I am entitled to two (2) weeks of vacation pay, $1,055 .78. 

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

Salary $6,387 .47 

Vacation $1,055 .78 

Total $7,443 .25 

Danielle Bales 

Cc: 

dock,Goldenberg,Schneider & Groh 

RECEIVED OCT 2 0 2003 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 21 of 43
May 25, 2004 

Ms. Danielle Bales 

7515 Winkler Drive 

Hamilton, OH 45011 

INTERNATIONAL 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Ms. Bales: 

R 

Intematioral Place i 

8400 Poplar Ave. 

Memptds, TN 38197 

Ptane 901 783 8000 

We are in receipt of your letter dated 10120/2003, in which you question your entitlement to 

vacation. 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 80 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 73-5 Filed 09/17/2004 Page 22 of 43
JOSEPH A.BERGERON 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 23 of 43
Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38197 

Dear Ms. Barger, 

GENE 

OCT 0 ? 2"_93 

D 26 September, 20113 

ADM. 

I am writing relative to the severance payout calculated by International Paper 

response to a ruling by Judge Beckwith in the civil case No. C-1-01-109, 

Dalesandro, et al. v. The International Paper Company. 

I believe International Paper's calculation relative to the Severance Pay amount due 

under Champion/International Paper's Reorganization Policy # 828 to be incorrect 

for the following reasons: 

l. The Section 2: Severance Benefits calculation is based on an incorrect number of 

years of "Credited Service". 

At the time of my termination in February 20011 had worked continuously for 

International Paper and its affiliated Companies (Union Camp and Champion 

International) for 20.5 years. Both Champion International and Union Camp 

were acquired by International Paper. My vested pension benef are now the 

responsibility of International Paper. Therefore I believe my Credited Service 

years should be 20.5 not the 4.1 years used in the calculation. 

Using 20.5 years in the Section 2: Severance Benefits calculation results in 36 

weeks of severance benefits. 

" (a) ten (10) weeks' Earnings; plus 

" (b) twenty and one half (20.5) weeks' Earnings for each year of Credited 

Service; phs 

" (c) Five and one half (5.5) weeks' Earnings for the 5.5 years of Credited 

Service over fifteen (15) years. 

2. The Section 7: Miscellaneous Benefits, paragraph 7.1 : Vacation Pay calculation 

was completely missing from the Exhibit A calculation . 

"Policy #828" provided for reimbursement for earned but unused vacation 

under Section 7, paragraph 7.1 . My years of service with International Paper 

entitled me to five (5) weeks of paid vacation each year. At the time of my 

termination from International Paper in February of 2001, I had earned in 2000 

but not taken in 2001, five weeks of vacation. Therefore, an additional five (5) 

weeks of severance pay is due as a result of earned but unused vacation. 

These two items taken together result in a total of 41 weeks of severance pay 

owed by International Patter under the terms and conditions of Champion/ 

International Paper Reorganization Policy # 828. 

RECEIVED OCT 0 7 2003 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 24 of 43
The #S2$ Severance Pay Amount due in total would be as follows: 

Age on 

February 9, 2001 

44 

Weekly Pay 

$2100 

Years of Service Weeks of Severance 

Section 2 Benefit : 20.5 36 

Weeks of Vacation Earned/Untaken 

Section 7.1 Benefit: 5 5 

Total Weeks of Severance Due 41 

#828 Severance Pay Amount: $86,100.00 

This calculation is consistent with the claim made by me in my original 

application letter for benefits submitted on January 7, 2002 and in my appeal of 

my original claim's denial dated April 17, 2002 in accordance with the provisions 

of Championdnternstional Paper's Reorganization Policy # 828. My original 

claim was denied-but the amount was not disputed. My appeal was denied but 

the amount was not disputed. 

oseph A. Bergeron 

242 North Ridge Drive 

Oxford, OH 45056-8867 

reply to my interpretation of the correct calculation for 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 25 of 43
May 25, 2004 

Joseph A. Bergeron 

242 North Ridge Drive 

Oxford, Ohio 45056-8867 

Dear Mr. Bergeron, 

Cordially, 

/Sib 

End. 

CC: File 

INTERNATIONAL 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

PAPER 

Re: Champion International Corporation Reorganization Severance Policy #828 

international Piece 1 

6400 Poplar Ave. 

Memphis, TN 38107 

Phone 901 763 6000 

We are in receipt of your letter dated September 26, 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. 

Severance benefits are calculated by using earnings and credited service as defined by the 

Plan. Section 1 .4 defines Credited Service as "an Eligible Employee's period of employment 

with the Company. . ." Section 1 .3 of the Plan defines Company as, "Champion International 

Corporation prior to the Merger (including it's United states subsidiaries), and after the Merger 

Company is the corporation that survives the Merger ." 

By definition, only your years of Champion service can be used in a calculation of estimated 

benefits under the Plan. Your request to have all of your years of service with Union Camp and 

Champion used in the calculation of your estimated severance from the Plan is denied . 

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. 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 26 of 43
RICK BERNARD 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 27 of 43
Octdrer 19, 2003 

Sbaxara Barger 

Intem;ational Paper 

64(KWoplar Avenue 

Memphis, Tennessee 38197 

Re: Dalesandro, vs International Paper 

Case No. C-1-01-109 

US District Court, Southern District of Ohio 

DeazMs Barger: 

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

ment-ers ate to notify you in writing of discrepancies in the calculation of our severance 

pay a a rd severance benefits of Severance Policy 828. 

You did indeed calculate my weeks of service correctly, but by my records my weekly 

pay is incorrect. The number of entitled weeks is 11 .01 at $1145.84 weekly for a total of 

$12,615.70. However you left off other pertinent benefits that was part of the entire 828 

packalre that I am eligible for, that being vacation pay and 9 months of COBRA 

covange. 

I amemtided to two (2) weeks of vacation pay totaling $2291 .67 

AND 

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

$2,173 .86. . 

This*ings the total owed to me from International Paper to: 

Salary $12,615.70 

vacation $2,291 .67 

Cobra $2,173 .86 

Total $17,081 .23 

RickBernard 

Cc:Nimiock,Goldenberg,Schneider & Groh 

RECEIVED OCT 2 2 2003 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 28 of 43
May 25, 2004 

Mr. Rick Bernard 

1216 Middletown-Eaton Rd. 

Middletown, OH 45042 

Dear Mr. Bernard: 

Cordially, 

INTERNATIONA 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

PAPER 

Re: Champion International Corporation Reorganization Severance Policy #828 

International Place I 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

We are in receipt of your letter dated 10122/2003, 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 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. 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 29 of 43
September 16, 2004 

Mr. Rick Bernard 

1216 Middletown-Eaton Rd. 

Middletown, OH 45042 

CORRECTION 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Bernard : 

International Place 1 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

We are in receipt of your letter dated 1012212003, in which you question the amount of the 

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

International Corporation Reorganization Severance Policy #828 ("the Plan") in addition to your 

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

A review of payroll records indicates you were paid on a semi-monthly basis. Your semimonthly pay was $2,291 .67, or $55,000.08 annually, which, according to the plan is $1,057.70 

per week for severance. 

As a result of our findings, no change will be made to the estimated severance benefit quoted in 

our previous communication . 

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 73-5 Filed 09/17/2004 Page 30 of 43
JEFFREY k. BETZ 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 31 of 43
October 7, 2003 

Sharon Banger : ; ; 

Intematiorial Paper 

6400 Poplar Avenue 

Memphis, TN 38197 

Dear Sharon 

In response the class action lawsuit brought against International Paper for our rights to severance 

benefits due to termination of employment by the International Paper Company, the calculations 

completed in Exhibit A are incorrect There are several thing that have not been included that I am 

entitled to under Champion International Paper Company Corporation Reorganization Policy #1828 

("Policy #828"). 

1 . The calculations made by International Paper for years of service were 3.65 yrs. Champion 

International Corporation's, and subsequently International Paper, policy was to credit a 

cooperative student with years of service if they came to work for the company after 

completing schooling from their original hire date. This was my case and my original hire date 

for International Pam is March 22, 1994. Based on Policy #828, 1 am entitled to one (1) 

weeks (or partial week's) Earnings for each year (or partial year) of Credited Service . Policy 

#828's definition of "Credited Service is an Eligible Employee's period of employment with the 

Company to and including the date of Termination, but not including years of service that have 

been taken into account for a prior severance payment from the Company." Please see 

attached sheet shaving my Original Hire date as shown on Intenatonel Papers HR System . 

This world modify my Years of Service in Exhibit A to 6.89 yrs. 

2 Section 7 of Policy #828 states drat "An Elite Employee will receive a lump sum payment for 

banked vacation, earned but unused vacation". Since International Papers' policy was to earn 

vacation during the year for the following year and since I had not used any vacation before 

termination in calendar year 2001, 1 am entitled to my earned but unused vacation 

three (3) weeks. 

3. Section 4 of Policy #828 states that "an eligible employee who elects COBRA coverage shall 

have the COBRA medical and dental premiums payments waived" . Sine I elected and paid 

COBRA Premiums from May 4, 2001 through July 27, 2001 when I became eligible for 

another plan, I am entitled to a refund of premiums paid at a rate of $22.95 per pay period for 7 

periods totaling $137.70. 

in conclusions, my entitled benefits to be paid as a result o Termination under Policy #828 would total 

(10 Weeks + 6.89 weeks for Credited Service + 3 weeks earned but unused vacation + $137.10). 

Based on my weekly pay o $1,115.39 this cones to : 

Sincerely, 

904 /&~ 

Jeffrey R. Betz 

Class Member 

Severance Pray Amount $22,32241 

Jeffrey R. Betz 

5651 Greenacres CL 

Cincinnati, OH 45248 

RECEIVE OCT 16 2003 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 32 of 43
September 8, 2004 

Jeffrey R. Betz 

5651 Greenacres Ct. 

Cincinnati, Ohio 45248 

Dear Mr. Betz, 

Cordially, 

Sharon L. Banger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

/sib 

End. 

CC: File 

INTERNATIONALW PAPER 

Re: Champion International Corporation Reorganization Severance Policy #828 

IntemaiWnai Place 1 

6400 P Ave. 

Memphis, TN 36197 

Phona 901 763 6QW 

We are in receipt of your letter dated October 7, 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 which reflects your co-op 

service. 

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 73-5 Filed 09/17/2004 Page 33 of 43
05/28/04 

ESTIMATED 

SEVERANCE PLAN STATEMENT 

POLICY 828 

JEFFREY R. BETZ 

, OH 

PREM PAPERS MILL OP 

002HAOH 

THIS ESTIMATE WAS BASED ON THE DEMOGRAPHIC INFORMATION 

ABOVE AND THE WEEKS OF SEVERANCE WERE BASED ON YOUR LAST 

DATE OF HIRE WITH THE COMPANY . IF YOU HAVE ADDITONAL 

SERVICE THAT MAY HE USED IN THE SEVERANCE CALCULATION, 

PLEASE SEE YOUR HUMAN RESOURCES REPRRSENTATIVE 

DATE : 06/16/95 

TERMINATION DATE : 02/09/01 

WEEKLY PAY: $1,115 .39 

YEARS OF SERVICE: 5 .65 

WEEKS OF SEVERANCE : 15 .65 

SEVERANCE PAY: $17,455 .86 

OR, IF GREATER, 

IP YEARS OF SERVICE : 6 

IP SEVERANCR WEEKS : 12 .00 

IP SEVERANCE PAY: $13,384 .68 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 34 of 43
DAVID J . BIEKER 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 35 of 43
October 15, 2003 

Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, Tenncssec 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 calculate my weeks of service and weekly pay correctly. That number of 48.92 

weeks at $ 1,153.85 for a total of $56,446.35 is correct, 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 nine months of COBRA coverage. 

I am entitled to six (6) weeks of vacation pay, $1,152 .85 x 6 for a total of $6,923 .10. 

Also, I do not know how much I paid into COBRA, if any. 

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

Sincerely, 

David 7. Bicker 

786 Millville-Oxford Road 

Hamilton, Ohio 

45013 

Cc: 

Murdock,Goldenberg,Schneider & Groh 

RECEIVED XT 7 0 2003 

Salary $56,446.35 

Vacation $6,923 .10 

Cobra you tell me 

Total $63,369.45 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 36 of 43
May 25, 2004 

Mr. David J. Bieker 

786 Millvillo-Oxford Rd. 

Hamilton, OH 45013 

Dear Mr. Bieker: 

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 I 

8400 Poplar Ave. 

Memptds, TN 38197 

Phone 901 783 6000 

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. 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 37 of 43
TOM BOKENO 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 38 of 43
October 14, 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. 

There are three specific components of the Severance Policy 828 that apply to my 

circumstance and should be included in the calculation of total benefits due. 

These include; 

1) Section 2, Severance Benefits . It appears that Section 2 Severance Benefits have been 

calculated correctly. Specifically, 12.74 years of service (22.74 weeks of severance) 

at $1,500 weekly pay, equates to a payment of $34,110 . 

2) Section 4, Cobra coverage was not included in your severance pay calculation. All 

payments made by me for Cobra coverage during the designated plan period should 

be included in the calculation of total severance benefits . 

3) Section 7.1, Vacations Pay was not included in your severance pay calculation. At the 

point of termination I had accrued 4 weeks of vacation at $1,500/week equaling a 

payment due to me of $6,000 . 

In summary, Section 2, Section 4, and Section 7.1 severance benefits should be included 

in the payment of total severance benefits to me provided by Policy 828. 

Cc: 

Murdock,Goldenberg,Schneider & Groh 

RECEIVED OCT 2 2 2003 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 39 of 43
May 25, 2004 

Mr. Tom Bokeno 

6094 Gray Road 

Fairfield, OH 45014 

INTERNATIONAL PAPER 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Bokeno: 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

International Place I 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

We are in receipt of your letter dated 10/21/2003, 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, 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 40 of 43
MARY BOWLING 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 41 of 43
October 23, 2003 

Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, TN 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 

22.53 weeks at $996.16 or $22,443.49, however you left off other pertinent benefits that 

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

I am entitled to four (4) weeks of vacation pay, $3,984.64 . 

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

Salary $22,443.49 

Vacation $3,984.64 

Total $26,428.13 

Sincerely, 

Mary 

Cc: Murdock, Goldenberg; Schneider and Groh 

Case 1:01-cv-00109-SSB Document 73-5 Filed 09/17/2004 Page 42 of 43
May 25, 2004 

Ms. Mary M. Bowling 

5484 Lakeside Drive 

Fairfield, OH 45014 

Dear Ms. Bowling: 

Cordially, 

INTERNATIONAL 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

PAPER 

Re: Champion International Corporation Reorganization Severance Policy #828 

Intemational Puce I 

6400 Poplar Ave. 

MempNs, TN 38197 

Phone 901 763 6000 

We are in receipt of your letter dated 11/3/2003, in which you question your entitlement to 

vacation. 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 73-5 Filed 09/17/2004 Page 43 of 43