Exhibit A 

Part 1 of 3 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 1 of 58
JOSEPH A.BERGERON 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 2 of 58
Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38147 

Dear Ms. Barger, 

OCT 0 ? 2"-33 

BE NE I TADM. 

D 26 September, 2003 

ting relative to the severance payout calculated by International Paper in 

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

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

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

under Championfinternationai Paper's Reorganization Policy # 828 to be incorrect 

for the following reasons: , 

1. 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 benefits 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 . 

Usine 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; plus 

" (e) Five and out half (5.5) weeks' Earnings for the 5.5 years of Credited 

Service over fifteen (15) years. 

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

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 &am 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 earn but amused vacation. 

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

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

International Paper Reorganization Policy # 828. 

RECEIVED OCT 0 7 2003 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 3 of 58
The #828 Severance Pay Amount due in total would be as follows : 

Age on 

Weekly Pay February 9, 2001 

$2100 44 

Years of Service Weeks of Severance 

Section 2 Benefit: 20.5 36 

Weeks of Vacation Earned/Untaken 

Section 7.1 Benefit: 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 ChampionUteruational Paper's Reorganization Policy # 828. My original 

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

the amount was notsAisputed. 

I await your favorable reply to my interpretation of the correct calculation for 

severance hen et due. 

oseph A. Bergeron 

242 North Ridge Drive 

Oxford, OR 45056-867 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 4 of 58
May 25, 2004 

Joseph A. Bergeron 

242 North Ridge Drive 

Oxford, Ohio 45056-8867 

INTERNATIONAL. PAPER 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Bergeron, 

International Place I 

6400 Poplar Ave. 

Memphis, TN 38197 

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 

man 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. 

Cordially, 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

/sib 

Encl. 

CC: File 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 5 of 58
RICK BERNARD 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 6 of 58
Octdrer 19, 2003 

Sharom Barger 

Intern-ational Paper 

6404Poplar Avenue 

Memphis, Tennessee 38197 

Dalesandro, vs International Paper 

Case No. C-1-01-109 

US District Court, Southern Dis of Ohio 

DearMs Barger. 

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

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

pay atd severance benefits of Severance Policy 828. 

Youd id indeed calculate my weeks of service correctly, but by my records my weekly 

pay B incorrect. The number of entitled weeks is 11.01 at $1145.84 weekly for a total of 

$12,625.70. However you left off other pertinent benefits that was part of the entire 828 

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

covesAge. 

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

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

$2,173 .86. 

T hisb4rings 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 

RickBemard 

AND 

Cc:Nsardock,Goldenberg,Schneider & Groh 

RECEIVED OCT 2 2 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 7 of 58
May 25, 2004 

Mr. Rick Bernard 

1216 Middletown-Eaton Rd. 

Middletown, OH 45042 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Bernard: 

INTERNATIONAL PAPER 

International Place 1 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

We are in receipt of your letter dated 10/2212003, 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 73-2 Filed 09/17/2004 Page 8 of 58
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 I 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

We are in receipt of your letter dated 10/22/2003, 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 73-2 Filed 09/17/2004 Page 9 of 58
JEFFREY R. BETZ 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 10 of 58
October 7,2003 

Sharon Barger ;f 

International 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 sever things that have not been included that I am 

entitled to under Champion International Paper Company Corporation Reorganization Policy #828 

('Policy #828") . 

Jeffrey R. Betz 

5651 Greenacres CL 

Cincinnati, OH 45248 : '. 

1 . The calculations made by International Paper for years of serves 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 wok for the company after 

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

for International Paper is March 22, 1994. Based on Policy #828, I am entitled to are (1) 

week's (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 riot Including years of service that have 

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

attached sheet showing my Original Hire date as shown on International Papers HR System. 

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

2. Section 7 of Policy #828 states that "An Eligible Employee will receive a lump sum payment for 

banked vacation, earned but unused vacafiW. 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, I am entitled to my earned but unused vacation totaling 

three . (3) weeks. 

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

have #w COBRA medical and dental premiums payments waived" . Since 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 of Termination under Policy #828 would total 

[10 Weeks + 6.89 weeks for Credited Service + 3 weeks earned but unused vacation + $137.101, 

Based am my weekly pay of $1,115.39 this conies to: 

My #828 Severance Pay Amount: $22,322 .81 

Sincerely, 

Jeffrey R. Betz 

Class Member 

CEIVED OCT 1 6 2003 . 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 11 of 58
September 8, 2004 

Jeffrey R. Betz 

5651 Greenacres Ct. 

Cincinnati, Ohio 45248 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Betz, 

INTERNATIONAL PAPER 

intema6onal Place 1 

6400 Poplar Ave. 

Memphls, TN 36197 

Phone 901 763 6000 

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. 

Cordially, 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

/sib 

Encl . 

CC: File 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 12 of 58
05/28/04 

ESTIMATED 

SEVERANCE PLAN STATEMENT 

POLICY 828 

JEFFREY R. BETZ 

HAMILTON, ON 

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 BE USED IN THE SEVERANCE CALCULATION, 

PLEASE SEE YOUR HUMAN RESOURCES REPRESENTATIVE 

HIRE 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 SEVERANCE WEEKS: 12 .00 

IP SEVERANCE PAY : $13,384 .68 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 13 of 58
DONALD R. BOYD 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 14 of 58
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. 

hi 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, 

oD"nald R. oB yy 

Cc: 

Murdock,Goldenberg,Schneider & Groh 

RECEIVED 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 73-2 Filed 09/17/2004 Page 15 of 58
May 25, 2004 

Donald R. Boyd 

4300 Lisa Lane 

Middletown, Ohio 45042 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Boyd, 

INTERNATIONALW PAPER 

Intemaflonal Place 1 

6400 Poplar Ave. 

Memphis, 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. 

Cordially, 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

/sib 

Encl. 

CC: File 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 16 of 58
Severance Calculation 

Age at 

February 9, 2001 

Weekly Pay Years of Service Tennination 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 73-2 Filed 09/17/2004 Page 17 of 58
RALEIGH BRUCE, JR. 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 18 of 58
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 7r. 

RECEIVED SEP 3 0 2003 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 19 of 58
Age at 

9,2001 

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 Pap Amount: $9,910.72 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 20 of 58
September 16, 2004 

Raleigh Bruce 

241 N Brookwood Avenue 

Hamilton, Ohio 45013 

Re : Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Bruce, 

Cordially, 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

/sib 

Encl. 

CC: File 

International Place t 

6400 Poplar Ave. 

Memphis, Thl 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") . 

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 . 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 21 of 58
09/ 07/04 

ESTIMATED 

SEVERANCE PLAN STATEMENT 

POLICY 628 

RALEIGH BRUCE JR 

HAMILTON, ON 

PREM PAPERS MILL OF 

002HAOH 

IP SEVERANCE WEEKS : 36 .00 

IP SEVERANCE PAY : $27,277 .20 

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 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, 

IF YEARS OF SERVICE : 18 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 22 of 58
Ftex6 Calculation for Raleigh Bruce Jr 

Social Security Number

Employee Data 

Social Security Number:

Name: Raleigh Bruce Jr 

Date of Birth: 8 

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: 02109/2001 

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: sup 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 73-2 Filed 09/17/2004 Page 23 of 58
SINGLE LIFE ANNUITY - You will receive a payment for your lifetime, 

payments stop at your death . 

50% CONTINGENT ANNUITANTUOINT & SURVIVING SPOUSE 

75% CONTINGENT ANNUITANT/JOINT & SURVIVING SPOUSE 

100% CONTINGENT ANNUTTANTUOINT & SURVIVING SPOUSE 

$503.52 5 YEAR CERTAIN 

$477.83 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 03/0112010 LEVEL INCOME OPTION - Thus option pays a larger benefit wage 62 

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

$0.00 thereafter Payments stop at your death. 

$724.95 to 03/0112013 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 at 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 to 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. 

If 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 annuitant 

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 It Plan Number: 001A 

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

Date Prepared : 0910712004 

Monthly Benefit Payable 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 24 of 58
SCHEDULE OF DEATH BENEFIT AFTER RETIREMENT 

DEATH BENEFITS AFTER RETIIRENIENT 

Amount From 

$5,000.00 03/01/2001 Thereafter 

Name Raleigh Bruce Jr Retirement Date 03101/2001 

Social Security Number Hire Date 08/24/1983 

Flan Number 001A Birth Date 

Date Prepared 09/0712004 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 25 of 58
BRENDA GAIL BURNS 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 26 of 58
September 25, 2003 

Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38197 

Regarding my severance pay calculation in Exhibit A, I am 

years of service calculation, and the weeks of severance. 

o disagree with the 

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 1-23-89 I 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: 

37 weeks a $688.47 = $25,473.39 

Regarding Section 7 Miscellaneous Benefits 7.1 Vacation Pay: At the time o£ 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 

Sincerely, 

Brenda Gail Burns 

1910 Amarillo Drive 

Hamilton, Ohio 45013 

and consideration in this matter. 

RECEIVED SEP 3 1 0 2003 

a) ten (10) weeks earnings plus: (10 weeks) $6,884 .70 

b) one (1) week (or partial weeks) earnings for each year (21 weeks) $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) 

years. 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 27 of 58
rnployee 

ction Farm 

- .Fist Name 'Middle Initial . : Effective Dr'v- 

!1R&NDA 6AT' '- . 510716 

s 

ei~+)iGL"a ddel 6Sr 

tt$ :' EtgOloyea-NoaSSN - Padi No .. Last PIR Chg. Date . ,, tast Pers. C 

Circie'Aetion Typefs) 1 .Salary Change 2 Pasiaon" Chimge, Transfer 4 Termmaaon=Retirement 5 . Leave of Absence 6 . Hire 7 . Re-Hire 8. To from Salaried 9. Current Intormatlen 

Business UnitlDepartmentllocation 

Business Urat Name Business Unit irvnenn L3 L4 L5 (Home Deptj LB` . PRINTING E WRITING PAPERS Mfr . HAMILTON OH PRHA 5430 8420 5430 PXHA'M 

sition l SalarylGradeISchedulef Range - 

	Otade sition Title- Schedule Range : Minimum Midpoint Ma)dmum Pay Code Pay Freg : FT/PT Std Hrs. 

5 N 35 IFR ' SECY DRUM DEPT 05' b86 66"i 

Annual ` Sim Rate.' Hrly. Rat " Admm. Oracle : Schedule Range. . Minimum Midpoint Maximum EEO Cat Pos. No. Next Sal Revi ew Date:. 18.250 e T60~42 8,.7744, : , 05 842000151 911016 , o ff 

Proposed Change Information (Complete Appil 

u. ~ 

Hdy N2Je lll - " .heat . Review Date (Effective Date v. C1hsnge AmoUnt~ . . Percent Increase . .'Change Type Prvi: Rafing . _9 .3509' t= , 920716 1901016 $ .700-00 3-99% . SI 3

. 

. . , :°. k. .vrc Pe` ns` ala :'Chart eD r`<<~" t r a ; :;147k? 

.Mao.._ ; Y 

Change Type Nn:'Pa

.

Hng Effective Date Change Amount Percent Increase Change . Type - Pert._ Rating 

I S1 I 4 1900116 $ 900.00 5-4],% SI 3 

L3 

Range Minimum Midpoint Maximum Pay Code Pay Frequency 

Std. 

HIM EEO Category 

Annual $ M Rate 

59,450 .00. $ 810 .42 

Y 

~ Change Amodnt, Percent Increase 

is 1,200.00 1 6 .57 % 

°Position-Change 

Position Tide 

C. Business UnitIDepartment/Locatloh Change 

New Business Unit Name New Business Unit Location 

O. Separation LOAILAYOFF 

Unused Vacation 

I days 

Remarks and Other Changes 

Approvals 

Initiated By : 

Mae Hacker 

Approved By 

Todd ODwney 

r 11 Champion 

v 01 L 

Accrued Vacation Severance Pay Deferred Vacation 

Term URelire male Retirement Status 

wksI 

-m to ment 

	e Pfior R ire- : .. p n^f T#M Dal 

T40401' 8211, 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 28 of 58
Corrlrne 

Initiated 

Approved 

Approved 

unused vacation 

Days MS 

Mr-red Vacallo 

Days 

Severance Pay 

Date 

Date 

Sustained Performance Level (Choose one "X") 

(yJ Doneletently exceeding expecationc surpassing established goals, and regulary 

making extraordinary contributions to the company . 

Fully skilled and Imomedgeable In all areas of responsibility, and consistently 

meeting the principal fob ob;edlree oft a sustained period of dyne . 

Acquiring the necessary siills and teaming eseenual job elements . 

NOT meetirt$ . erforrnance expectations 

Keyed by: Date 

Date f~ iP Approved 

Date r 4 Approved 

Date Approved 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 29 of 58
REFQRTING 

?ayFiegiy 

!5 acF 

21,542 - 24,415 - ,'.7,287 - 34,159 

%pproved By: 

rpnMs 

Date /:',1,ZA/ 93 

Approved By : 

: . . Date ~ Q! A 4, .9:3. 'Approved By: 

Date . . ..1 . I Approved By: 

on -International 

Negtiva. 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 30 of 58
aided performance level (Choose one "X") 

nsistlintly exceeding expectations, surpassing established goals, and regularly making extraordinary 

nributibnato the company. 

( I Kully skilled and knowledgeable In all areas of responsibility, and consistently meeting the princip 

job objectives for a sustained period of time, 

( } Acquiring the necessary skills and learning essential job elements. 

NOT meeting performance expectations. 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 31 of 58
May 25, 2004 

Brenda G. Burns 

1910 Amarillo Drive 

Hamilton, Ohio 45013 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Ms. Bums, 

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. 

Cordially, 

INTERNATIONAL 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

/sib 

Encl. 

CC: File 

PAPER 

Intemational Place 1 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 32 of 58
Severance Calculation 

Age at 

February 9, 2001 

Weekly Pay Years of Service Termination Weeks of Severance 

$688.41 21 45 42 

#828 Severance Pay: $28,915.14 

Exhibit A 

Brenda Burns 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 33 of 58
CARLA GATHERS 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 34 of 58
October 15, 2003 

Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, Tennessee 38197 

Sharon, 

After reviewing my severance pay calculation under policy #828, I have found a 

discrepancy. My last salaried position with International Paper was an Inside Sales 

Representative that paid an annual salary of $37,600. 

The weekly pay should be' $783.33, not $723.08. My calculation for the severance pay 

amount should be $16,081.76. The severance did not include my 3 weeks of earned, 

but unused vacation, which should be a total of $2,344 .99. 

Also, an additional estimated Cobra Medical for 9 months at an approximate rate of 

$615.00 per month, along with Cobra Medical an approximate rate of $100 per month for 

Cobra Dental. The total estimation for Cobra Medical and Dental should be in the 

range of $6,435.00. 

The severance pay amount of $16,081.76, three weeks of earned, but unused vacation of 

$2,349.99, along with the estimation for Cobra Medical and Dental of $6435.00, should 

bring the grand total to $24,866.75. 

Please submit your return correspondence to the following address: 

Carla Cathers 

492 Tracy Lane 

Hamilton, Ohio 45013 

Thank you, 

Carla Cathers 

RECEIVED OCT 2 0 2003 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 35 of 58
May 25, 2004 

Carla Cathers 

492 Tracy Lane 

Hamilton, Ohio 45013 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Ms. Cathers, 

INTERNATIONAL 

International Place 1 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

We are in receipt of your letter dated October 15, 2003, 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") as well as entitlement to vacation pay and 

reimbursement for COBRA coverage . The following will explain the results of our research. 

A review of payroll records indicates you were paid on a semi-monthly basis. Your semi-monthly pay was 

$1,566 .67, or $37,600.08 annually ($1,566.67 x 26 = $37.600 .08), which is $723.08 per week for 

severance ($37,600 .08 / 52 = $723.08) . 

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 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 

/sib 

CC: File 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 36 of 58
GARY W. ELLIOTT 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 37 of 58
October 11, 2003 

Sharon Barger 

International Paper 

6400 Poplar Avenue 

Memphis, TN 38197 

RE: Gary W. Elliott 

Dear Ms. Barger, 

I recently received notification of the court ordered notice of rights to severance 

due to the termination of employment by International Paper Company in regard to the 

Hamilton, Ohio mill. 

After reviewing my-husbands payroll information I have found that there is a difference 

in the calculation of my husbands severance. I am sending along a payroll deposit 

notification dated l-16-01. His earnings for that period of two weeks is $3,879 .17. For a 

one week period it would be $1939 .59. In the letter that I received his income was 

reported as $1,790 .39. This is a difference of $149.20. 

My husband passed away on April 3, 2001 and I was Gary's wife and beneficiary. Any 

further correspondence regarding this matter can be addressed to reflect that. Thank you 

for your attention to this matter and I will look forward to your response. 

Mary Jane Elliott 

71 Brook Rd. 

Portland, ME 04103 

Enclosure (1) 

RECEIVED 

OCT 13 2003 

BENEFITS ACM. 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 38 of 58
CC 5A MMHA 5430 4500 

GARY W ELLIOTT 

3 RUTLEDGE COURT 

HAMILTON ON 45013 

RECL-m 

OCT 13 200 

NEFITS ADS 

PAYROLL DEPOSIT ADVICE ONLY - NON NEGOTIABLE 

STATEMENT Or EARNINGS AND DEDUCTIONS RETAIN FOR YOUR RECORDS 

a 

0 

L011tKNAIII-IIIAL PAPER rLLIU414 %14: Am I . . I 

.~ 

I ., 

CC5A DERAL TAX 

SOCIAL SEC TAX Tim 48DE 

%EIGNU t X R, '"HWAN 

'N"S el'CRI-l RR" 0 MEDICARE TAX %2 ,112,4 

i -f,'lb8;320HIO 1696f. '3393 

BENEFIT $'S-1 I 11200E 24011 E HAMILTON 749

_

: :1549 

BENEFIT $'S-2 ;2345C :4590(LTD 

i 

4g~ j 

~1B5Q 

85;3 

UNIV . MET LIFE 829 

GROUP LIFE 36.41 79.8 

POL ACTION COM 10041- 200 

PRETAX DENTAL 3a~ ,~# 61:0 

PRTAX GRP LIFE 13,04, 2610 

PRTAX SLRY SAY :2327~ :4655 

PRTAX OCMED :31g541 : ;625;0 

UNITED WAY 50& 10,0 

DIR DEP CHK ~24Q51 

t I 

4492,'9 

I 

I I I I 

i I 

t I I 

I 

. 

I I , 

I J 

YEAR TO DAM vo 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 39 of 58
May 25, 2004 

Mary Jane Elliott 

71 Brook Road 

Portland, ME 04103 

Dear Mrs. Elliott, 

INTERNATIONAL 

Re: Gary W. Elliott 

Champion International Corporation Reorganization Severance Policy #828 

We are in receipt of your letter dated October 11, 2003, 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") . The following will explain the results of our research. 

A review of payroll records indicates Mr. Elliott was paid on a semi-monthly basis. The 

check stub that you provided in your correspondence was for the pay period of January 

16 through January 31, which is a semi-monthly not a bi-weekly pay period . His semimonthly pay was $3,879 .17, or $93,100.08 annually, which, according to the plan is 

$1790.39 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. 

Cordially, 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

/sib 

cc: File 

PAPER 

International Place I 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 40 of 58
RICHARD W. EMERY 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 41 of 58
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 benefits under Severance Policy 828. 

You did not calculate my weeks of service correctly, although the weekly pay was indeed 

correct. My years of service should be 16.33, rather than the claimed 9.08. I worked at 

the Hamilton Mill for Champion from 1979 until 1986, then returned to that location in 

1992 and worked there until being terminated by IP. My years of service were given 

back to me in their entirety by Champion, and must be included now as well . Based on 

a corrected number of 16.33 actual years of service, this converts into 17.66 years plus 

the standard 10 weeks for all covered employees, for a total of 27.66 weeks. At 

$1278.85/wk, this will equal $35,372.99 for salary alone; however, you left off another 

pertinent benefit that was part of the entire 828 package which I am eligible for, that 

being vacation pay. (I had no COBRA payments, having declined that coverage.) 

I am entitled to four (4) weeks of vacation pay, which equals $5115.40. 

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

Salary $35,372.99 

Vacation $5.115.40 

Total $40,488.39 

Richard W. Emery 

2435 Sir Martin Drive 

Hamilton, OH 45013 

Cc: 

Murdock,Goldenberg,Schneider & Groh 

RECEIVED OCr 2 8 2003 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 42 of 58
May 25, 2004 

Richard W. Emery 

2435 Sir Martin Drive 

Hamilton, Ohio 45013 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Emery, 

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. 

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. 

Cordially, 

INTERNATIONAL 

Sharon l. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

(sib 

Encl. 

CC: File 

IntemaUonal Place 1 

6400 Poplar Ave. 

Memphis, TN 36197 

Phone 901 763 6000 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 43 of 58
Severance Calculation 

Age at 

February 9, 2001 

Weekly Pay Years of Service Termination Weeks of Severance 

$1278.85 16 45 32 

#828 Severance Pay: $40,923.20 

Exhibit A 

Richard Emery 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 44 of 58
Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 45 of 58
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. 

You did indeed calculate my weekly pay correctly. That number is $ 1,453 .85. However you 

left off other pertinent benefits that were part of the entire 828 package that I am eligible to 

receive. Specifically, I am eligible for vacation pay, 9 months of COBRA coverage, and 

ional years of service were not correct. 

I am entitled to four (4) weeks of vacation pay, $5,815 .40. 

I -am entitled to 9 months of Cobra at ($71 .73 medical & $16.40 dental per pay) for 19.5 pay 

periods (bi-weekly pay) or $1,718.53. 

You listed my Years of service as 5.83. However, others who received the package received 

credit for their prior years of service with IP even though they were with Champion at the time of 

the merger. My original start date with IP was 511988 . My years of credited service should be 

12.75, not the 5:83' you had indicated. Combined with the 10 years added in the package, my 

total years should be 22.75, resulting in a total of $33,075.09. 

This brings the total owed to me from International P 

Cc: 

Murdock, Goldenberg, Schneider & Groh 

RECEIVED OCT 2 0 2003 

Salary $33,075.09 

Vacation $ 5,815.40 

Cobra $ 1,718.53 

Total $40,609.02 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 46 of 58
May 25, 2004 

Mr. Kenneth G. Kaup 

541 Fairhaven Dr. 

Hamilton, OH 45013 

Dear Mr. Kaup: 

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 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 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 73-2 Filed 09/17/2004 Page 47 of 58
Mr. Kenneth G. Kaup 

541 Fairhaven Dr. 

Hamilton, OH 45013 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Mr. Kaup: 

CORRECTION 

International Place I 

6400 Poplar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

We are in receipt of your letter dated 10/20/2003, in which you question 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") and your entitlement to vacation and/or COBRA. 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 its 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 International Paper Company 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 . 

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 Papers 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 

/sib 

Encl . 

CC: File 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 48 of 58
BARBARA M. LEHMAN 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 49 of 58
Sharon Barger 

International Paper 

6400 Poplar Ave. 

Memphis, Tennessee 38197 

October 3, 2003 

Dear Ms. Barger, 

I recently received from Theresa Groh, of Murdock Goldenberg 

Schneider & Groh, the enclosed Severance Pay Calculation Under Policy #828 

pursuant to class action lawsuit Dalesandro, et al v. The International Paper 

Company. 

I believe the calculation to be in error due to the years of service listed . 

I was employed by Champion International/International Paper from Jan. 

1, 1974 through October 1978 for 4.75 years. Then I was employed from 

November 9, 1981 through termination on February 9, 2001 for 19.25 year. This 

leads to 24 years of service. The 24, not 19.25, years of service were used for all 

things before the divestiture, including vacation time, years of service and 

retirement calculations . Twenty-four (24) years of service leads to 43 Weeks of 

Severance. (Ten (10) weeks regular earnings plus twenty-four (24) weeks for each 

year of Credited Service plus nine (9) weeks for each year over fifteen years.) 

This will increase my severance amount to $52,344.33. 

I request that you please review and resolve this discrepancy. My daytime 

phone number is 513-869-5033 . 

6664 Wayne Trace Rd 

Somerville Oh 45064 

RECEIVE, nr.T 0 8 2003 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 50 of 58
YOUR SEVERANCE PAY CALCULATION UNDER POLICY #828 

Age at 

February 9, 2001 

Weekly. Pay Years of Service Termination Weeks of Severance 

$1,217.31 19.25 55 33 .50 

Your #828 Severance Pay Amount: $40,779.89 

Your Flex Six Enhancement: 

Since International Paper Company's records indicate that you were age 49 or older and your age 

and service equaled at least 59 as of February 9, 2001, if the Court of Appeals upholds Judge 

Beckwith's decision, your monthly benefit under the Retirement Plan will be enhanced as 

indicated below. The amounts below reflect the benefits payable on a retirement as of February 

9, 2001 and assume that the benefit is received as a single life annuity. 

Monthly Benefits Without Flex Six: 

Monthly life annuity of $1,443 .73 payable at normal retirement date 

x Early retirement factor 0.696 

=Monthly life annuity of $1,004 .84 payable 21912001 

Monthly Benefit With Flex Six: 

Section 7 .4(b) of the Champion Salaried Retirement Plan #0001 and its successor, the 

Retirement Plan of International Paper Company (the "Retirement Plan"), provides that the 

"Benefit Commencement Date" of a retiring employee can be any time after age 55 provided that 

a participant is not employed by Champion (now International Paper Company) or an affiliate or 

"with respect to a Participant who worked at a divested location, by any purchaser of such 

location." It is International Paper Company's position that since Smart Papers, LLC is a 

purchaser of a divested location under the Retirement Plan, an affected participant cannot start 

benefits until after the end of your employment with Smart Papers, LLC. Without Flex Six, the 

date you can obtain benefits is determined under the terms of the Retirement Plan. For more 

information about the Retirement Plan, refer to your Summary Plan Description or contact: 

Sharon Barger 

International Paper 

6400 Poplar Ave 

Memphis, Tennessee 38197 

(06008540:4) 

Exhibit A to Class Notice 

Barbara M. Lehman 

Monthly life annuity of $1,443 .72 payable at normal retirement date 

x Early retirement factor 0.984 

= Monthly life annuity of $1,420 .62 payable 21912001 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 51 of 58
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. 

As outlined in the attached letter you miscalculated my year of service compensation. 

That number should have been 43 weeks at $ 1217.31 or $52344.33 . Also, 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, $6086.55. 

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, 

Leuman 

664 Wayne Trace Rd 

Somerville, Ohio 45064 

Cc: 

Murdock,Goldenberg,Schneider & Groh 

RECEIVED OCT 2 0 2003 

Salary $52344.33 

Vacation $ 6086.55 

Cobra $ 2173.86 

Total $60604 .74 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 52 of 58
May 25, 2004 

Barbara M. Lehman 

6664 Wayne Trace Road 

Somerville, Ohio 45064 

INTERNATIONAL PAPER 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Ms. Lehman, 

International Place 1 

6400 Poptar Ave. 

Memphis, TN 38197 

Phone 901 763 6000 

We are in receipt of your letters dated October 3, 2003, and October 9, 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 Wit 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 years of service used for your retirement calculation. Your benefit 

was calculated using 23.96 years of credited service. This does include your previous period of 

employment with the company, therefore there will be no change in your retirement calculation. 

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 

/alb 

Encl . 

CC: File 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 53 of 58
Severance Calculation 

#828 Severance Pay. $60.865 .50 

Flex Six Enhancement: 

Monthly Benefits Without Flex Six: 

Monthly Benefit with Flex Six: 

Exhibit A 

Barbara M. Lehman 

Age at 

February 9, 2001 

Weekly Pay Years of Service Termination Weeks of Severance 

$1,217 .31 25 55 50 

Because you were age 49 or older and your age and service equaled at least 59 as of February 9, 2001, if the court's 

ruling that you are entitled to benefits is upheld following appeals, your monthly benefit under the Retirement Plan 

will be enhanced as follows. The amounts below reflect the benefits calculated as of February 9, 2001, on a single 

life annuity basis. 

Monthly life annuity of $1,443 .73 payable at normal retirement date 

X Early retirement factor 0.696 

= Monthly life annuity of $1,004 .84 payable 2/9/2001 (subject to the blocking provision) 

Monthly life annuity of $1,443 .72 payable at normal retirement date 

X Early retirement factor 0.984 

= Monthly life annuity of $1,420.62 payable 2/9/2001 (subject to the blocking provision) 

Section 7.4(b) of the Champion Salaried Retirement Plan #001 and its successor, the Retirement Plan of 

International Paper Company, provides that the "Benefit Commencement Date" of a refiring employee can be any 

time after age 55 provided that a participant is not employed by Champion (row IP) or an affiliate or "with respect 

to a Participant who worked at a divested location, by any purchaser of such location". Because Smart Papers is a 

purchaser of a divested location under the Retirement Plan, an affected participant cannot start benefits until 

terminating employment with Smart Papers . This blocking provision applies whether or not you receive the Flex 

Six benefits . For more information about the Retirement Plan, refer to your Summary Plan Description or contact 

the Employee Service Center at 1(888) ESC-2YOU. 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 54 of 58
MARYLOUDEN 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 55 of 58
October 20, 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 

Barger: 

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 at 13 .52 correctly, however my weekly pay 

should be at $987.58. (My bimonthly rate was $2139.75.) Therefore 13.52 weeks at 

$987.58 is $13,352.08. 

Also, 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 two (2) weeks of vacation pay, $1,975 .16. 

Also 9 months of Cobra at ($95 .63 medical & $25.14 dental per pay) for 18 pay periods 

or $2,173 .86. 

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

F ely, ary Loth 

Cc: 

Murdock,Goldenberg,Schneider & Groh 

RECEIVED OCT 2 4 2003 

Salary $13,352.08 

Vacation $1,975 .16 

Cobra $2,173 .86 

Total $17,501.10 

Case 1:01-cv-00109-SSB Document 73-2 Filed 09/17/2004 Page 56 of 58
May 25, 2004 

Ms. Mary C. Louden 

7312 Bernard Avenue 

Cincinnati, OH 45231 

Cordially, 

INTERNATIONALW PAPER 

Re: Champion International Corporation Reorganization Severance Policy #828 

Dear Ms. Louden: 

Sharon L. Barger 

Benefits Consultant, Employee Benefits 

Office of the Plan Administrator 

Intenationai Place I 

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 73-2 Filed 09/17/2004 Page 57 of 58
Ms. Mary C. Louden 

7312 Bernard Avenue 

Cincinnati, OH 45231 

CORRECTION 

Re: Champion intemational Corporation Reorganization Severance Policy #828 

Dear Ms. Louden: 

International Place I 

6400 Poplar Ave. 

Mernpiro, TN 36197 

Phone 901 763 6000 

We are in receipt of your letter dated 10/24/2003, in which you question the amount of the 

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

Intemational Corporation Reorganization Severance Policy #828 ("the Plan") and 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 semi-monthly 

pay was $2,054 .17, or $49,300.08 annually, which, according to the plan is $948.08 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 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 73-2 Filed 09/17/2004 Page 58 of 58