UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

 

In re:                                                                                        )

                                                                                                )

UNITED AIR LINES, INC., et al.,                                       )

                                                                                                )

                                    Debtors.                                              )

                                                                                                )                                                          

PENSION BENEFIT GUARANTY CORPORATION,      )

                                                                                                )

                                    Plaintiff,                                              )  Chapter 11

                                                                                                )

                                    vs.                                                        )  Case No. 02-B-48191

                                                                                                )  (Jointly Administered)

UNITED AIR LINES, INC., as Plan Administrator for       )

the United Airlines Pilot Defined Benefit Pension Plan,       )  Adversary Proc. No. 05-481

                                                                                                )

                                    Defendant,                                          )

                                                                                                )  Honorable Eugene R. Wedoff

AIR LINE PILOTS ASSOCIATION,                                  )

INTERNATIONAL, UNITED RETIRED PILOTS             )

BENEFIT PROTECTION ASSOCIATION,                        )

ROGER D. HALL, DENNIS D. DILLON, GERARD       )

TERSTIEGE, EUGENE M. CUMMINGS, RAYMOND    )

P. FINK, JAMES M.  KRASNO and WILLIAM L.            )

RUTHERFORD,                                                                    )

                                                                                                )

                                    Intervenors.                                         )

 

EMERGENCY MOTION OF THE UNITED RETIRED PILOTS BENEFIT PROTECTION ASSOCIATION FOR A STAY PENDING APPEAL OF

THE JUDGMENT ENTERED IN FAVOR OF THE PENSION

BENEFIT GUARANTY CORPORATION AND TO ALLOW FOR THE

CONTINUED PAYMENT OF ALL PENSION BENEFITS TO RETIRED PILOTS

 

The United Retired Pilots Benefit Protection Association and Roger D. Hall, Dennis D. Dillon, Gerard Terstiege, Eugene M. Cummings, Raymond P. Fink, James M. Krasno and William L. Rutherford (collectively referred to as “URPBPA”), hereby moves this Court, pursuant to Bankruptcy Rule 8005 and the other authorities cited below, to enter an order staying the enforcement and effectiveness of the October 26, 2005 judgment entered in favor of the Pension Benefit Guaranty Corporation (the “PBGC”) and against the defendants and intervenors so that full and uninterrupted pension payments can continue.  In support of its motion, URPBPA states as follows:

I.          Introduction

On October 26, 2005, this Court entered its Order Terminating The United Airlines Pilot Defined Benefit Pension Plan and its Memorandum of Decision which states that the PBGC met its burden of proof in the “involuntary termination” case under 29 U.S.C. § 1342(c).  URPBPA will appeal the order and will seek an expedited briefing and decision schedule from the reviewing courts.  The order should be stayed while URPBPA’s appeal is pending and all pension payments (including all tax-qualified and non tax-qualified pension payments) to United’s retired pilots should continue until the appeal is resolved.  The prior order of this Court approving the agreement between the PBGC and United calls for the continuation of the Pilot Plan until conclusion of this litigation and the litigation has not concluded because URPBPA is appealing this Court’s judgment.  While United should be required to continue maintaining the entire Pilot Plan, there are additional reasons why the payment of non-qualified pension payments should continue.  First, the conditions that are set out for the termination of the Pilot Plan under this Court’s order Letter Agreement 05-01 between ALPA and United have not been met and, second, United has no legal justification to support its decision to stop paying non-qualified pension benefits to retired pilots.  URPBPA also satisfies the test for a stay order under Rule 8805 and the applicable case law. 

This motion is an emergency in light of the due date for URPBPA’s appeal of the termination order, November 7, 2005, and the immediate harm to retired pilots whose pension payments will be decreased.

 

II.        Relevant Factual Background

A.        The Filing Of The PBGC’s Case And The Discovery Dispute

The PBGC filed this case on December 30, 2004.  From the earliest stages of this litigation, the parties disputed whether the PBGC’s decision to seek the termination of the Pilot Plan was entitled to some type of judicial deference or, on the other hand, the PBGC had to prove, by a preponderance of the evidence, that “the plan must be terminated in order to…avoid…any unreasonable increase in the liability of the fund.”  29 U.S.C. § 1342(c).    

            On March 16, 2005, ALPA, United, the PBGC and URPBPA filed their Pretrial Statement (a copy of which is attached as “Exhibit A.”)  The Pretrial Statement shows that the parties only agreed on 15 limited factual statements (see § C.1 on pages 21-24) and it also shows that the parties had different views regarding whether discovery should be permitted in this case.  As a result, the parties briefed the issue of whether, and to what extent, the PBGC should be required to produce discovery and oral argument regarding the discovery issue was conducted before the Court during an April 13, 2005 hearing.  A copy of the transcript from that hearing is attached hereto as “Exhibit B.” 

            During the April 13, 2005 hearing, the Court observed, based upon the statutory language and legislative history of 29 U.S.C. § 1342, that the PBGC should be required to prove, at a de novo trial, that it is entitled to prevail under the standard set forth at § 1342(c).  In addressing the attorney for the PBGC, the Court stated “I think you would agree with me if the statute sets up a situation in which the agency is a plaintiff in a judicial action, that it ought to have the same burden of proof that any plaintiff in a judicial action would have without any statutory indications to the contrary” (Exhibit B, pp. 14-15).  Although the Court provided a number of other reasons why it believed the PBGC had an obligation to prove at trial, and by a preponderance of the evidence, that it is entitled to relief under § 1342(c), the Court permitted discovery but did not make a definitive ruling regarding the applicable standard of review at that time.

            B.        The PBGC’s Motion For Summary Judgment

            On May 20, 2005, the Court gave the PBGC leave to file a motion for summary judgment arguing the limited issues of (1) whether the standard of review in this case is an “arbitrary or capricious” standard of review under the Administrative Procedures Act and (2) whether under that standard the administrative record supports the PBGC’s determination.  On August 26, 2005, the Court preliminarily ruled that the PBGC’s motion for summary judgment regarding the standard of review would be denied and that, consistent with § 1342(c), “the burden of proof is on the PBGC to establish the propriety of termination under the statutory grounds by a preponderance of the evidence”.

            On September 21, 2005, the trial began.  In addition, on September 21, 2005, the Court issued its Memorandum of Decision (the Court issued an amended memorandum opinion on October 26, 2005) regarding the PBGC’s motion for summary judgment, which was entirely consistent with the Court’s August 26, 2005 preliminary ruling.  The Court’s amended memorandum decision stated at page 14 that “[b]ecause there are factual disputes over whether the termination of the Pilot Plan is appropriate…a trial on that question is necessary…[and] [a]s any plaintiff in typical civil litigation, PBGC will have the burden of proof at trial under a preponderance of the evidence standard”. 

            C.        The Kramer Report And Other Documents Admitted Into Evidence At Trial

            All of the Court’s evidentiary rulings were made on September 21, 2005, the only day trial testimony was taken (see September 21, 2005 trial transcript, attached hereto as “Exhibit C”).  A key exhibit was the Declaration and Expert Report of Michael A. Kramer (the “Kramer Report”), contained within ALPA trial exhibit 4.  The Kramer Report shows that, on December 28, 2004, the PBGC’s own financial expert believed that United had failed to demonstrate that it would not be able to afford to continue the Pilot Plan.  Kramer states that “even on United’s own terms, it has failed to carry its requisite burden to demonstrate that it must terminate all of the Pension Plans to successfully reorganize and avoid liquidation” (ALPA Exhibit 4 at AR 102-03). 

            Kramer explains that even “applying United’s own methodology and using its own numbers, my analysis suggests that United can substantially achieve most, if not all, of its targeted credit metrics in a variety of scenarios where it retains some combination of Pension Plans” (ALPA Exhibit 4 at AR 116).  Even though Kramer was “not convinced that United cannot obtain exit financing unless its business plan shows it surpassing the Snyder Declaration’s suggested targets for each of the credit metrics listed in the paragraph above,” the Kramer Report shows that, at the time the PBGC decided to seek the termination of the Pilot Plan, United could have satisfied all of its own financial metrics if it retained the defined benefit plans for the flight attendants and the pilots.  For instance, the Kramer Report shows that the there would be very little difference between United’s fixed charge coverage ratios under a scenario where United terminated all of its defined benefit plans as opposed to a scenario where United continued to maintain its plans for its flight attendants and pilots.

            The Kramer Report demonstrates that, at the time the PBGC decided to terminate the Pilot Plan, it was the PBGC’s position that United had failed to demonstrate that the Pilot Plan needed to be terminated in order for United to obtain adequate exit financing and reorganize.  Not a single document admitted into evidence contradicts Kramer’s position. 

            D.        Trial Testimony, URPBPA’s Motion For

                        Directed Finding and Trial Conclusion

            Likewise, none of the testimony presented at trial supported the PBGC’s position that when it made its decision to seek termination, the Pilot Plan was likely to terminate.  None of the trial witnesses presented testimony regarding whether United could afford to continue paying for the Pilot Plan. 

            The only witnesses permitted to testify on behalf of the PBGC, Karen Justesen (Exhibit C, pp. 33-57, 136-44) and Thomas Lowman (Exhibit C, pp. 57-68, 144-162), testified regarding the PBGC’s actuarial calculations and their opinions that the amount the PBGC’s unfunded benefit liabilities would change over time.  Although the PBGC sought to introduce additional testimony from a PBGC attorney, Charles Finke (Exhibit C, pp. 79-94), regarding the reasons why the PBGC decided to seek the termination of the Pilot Plan, this testimony was properly held to be inadmissible (see Exhibit C, pp. 86-92). 

            Because the PBGC failed to submit any evidence regarding whether the increase in the PBGC’s liability would be unreasonable in light of the financial condition of United and the Pilot Plan, URPBPA moved for a directed finding, pursuant to Federal Rule of Civil Procedure 52(c), after the PBGC presented its case and rested (see Exhibit C, p. 94-96).  The Court stated that it would reserve its ruling on the issue and the trial proceeded.

            ALPA and URPBPA presented their witnesses.  Paul Rusin, ALPA’s actuary, testified (Exhibit C, pp. 97-126, 163-64) regarding the PBGC’s liabilities with respect to the Pilot Plan.  Thomas Levy, URPBPA’s actuary, provided testimony (Exhibit C, pp. 127-129) regarding URPBPA’s “Split-Freeze Plan” and Roger Hall, the President of URPBPA, testified (Exhibit C, pp. 130-135) that URPBPA has been willing and able, throughout United’s bankruptcy proceedings, to defend against any attempt made by the PBGC or United to terminate the Pilot Plan. 

            The Court heard closing arguments on September 22, 2005 (the transcript is attached hereto as “Exhibit D”).  The attorney for the PBGC argued that “the facts as of December 2004 when the PBGC determined that the pilot plan should terminate…show without a doubt that the termination of the pilot plan was not only possible, the standard that’s in Section 1342, but also likely, if not inevitable” (Exhibit D, p. 6).  She also argued that “the real crux of the argument here is not on the actuarial evidence.  It is on the legal argument of what constitutes an unreasonable increase in liability” (Exhibit D, p. 8). 

            The problem with the PBGC’s closing argument is that it was fundamentally inconsistent with the evidence that was actually entered into evidence at trial.  Nearly all of the PBGC’s admissible evidence consisted of testimony from and documents created by the PBGC’s actuaries.  Not one piece of evidence introduced at trial, by the PBGC or any of the other parties, supported the PBGC’s argument that the termination of the Pilot Plan was “inevitable.”  The testimony of Roger Hall showed that URPBPA would have fought any effort by United or the PBGC to terminate the Pilot Plan and, as a result, the termination of the Pilot Plan was not “inevitable” or “likely.”  The PBGC’s own Kramer Report demonstrates that United had the financial ability to continue maintaining the Pilot Plan.

            H.        The Court’s Written Opinion And Termination Order

On October 26, 2005, this Court issued its written opinion (a copy is attached hereto as “Exhibit E”) and entered an order terminating the Pilot Plan and appointing the PBGC as the statutory trustee of the Pilot Plan (a copy of the order is attached hereto as “Exhibit F”).  In its opinion, the Court observed that “real issue” in the case is whether the PBGC has satisfied the § 1342(c) standard by demonstrating that it needed to terminate the Pilot Plan in December 2004 to avoid an “unreasonable increase” in the PBGC’s liability (Exhibit E, p. 5).  The Court observed that in order to satisfy this standard, the PBGC is required to show: (1) that the PBGC will suffer “a monetarily significant increase in PBGC’s liability” if the plan is not terminated and (2) that the plan is “likely to terminate in an underfunded condition, so that the increase in liability would be reflected in an actual additional loss for PBGC’s insurance fund” (Exhibit E, p. 6).

In applying a two-part test for “unreasonable increase in liability” the Court ruled that the actuarial testimony related to the increased liabilities related to the Pilot Plan demonstrated that the increase in Pilot Plan liabilities after December 2004 were monetarily significant.  The Court’s ruling on the second issue (whether the Pilot Plan was likely to terminate) is as follows:

Second, the only evidence bearing on the issue indicates that the Pilot Plan would not continue.  PBGC’s administrative record reflected United’s repeated statements in this case that termination of all of its defined benefit plans would be necessary for it to reorganize successfully, and United’s agreements with ALPA and the PBGC contemplated such a termination.  Accordingly, even though no witness testified on the subject, PBGC sustained its burden of establishing the likelihood of plan termination.

 

(Exhibit E, p. 9). 

I.          The Relief Requested Here Is Consistent With This Court’s Orders Approving And Incorporating The PBGC-United Agreement And

The ALPA-United Agreement                                                               

 

This Court approved Letter Agreement 05-01 between ALPA and United on January 31, 2005.  A copy of the order approving Letter Agreement 05-01 and the letter agreement itself are attached hereto as “Exhibit G.”  In addition, the Court approved the Settlement Agreement By and Among UAL Corporation and all Direct and Indirect Subsidiaries and Pension Benefit Guaranty Corporation on May 11, 2005 (a copy of the order approving the agreement is attached hereto as “Exhibit H”).  These agreements show that no portion of the Pilot Plan should be terminated and support URPBPA’s request for a stay order.

The agreement between the PBGC and United shows that an order staying the actual termination of the Pilot Plan is appropriate because the termination of the Pilot Plan is premature.  The PBGC-United agreement makes clear that as agreed upon by PBGC and United and approved by the Court, the format for any termination of the Pilot Plan would be via a trusteeship agreement.  (Exhibit H, par. 4c).  Exhibit 2 to the PBGC-United agreement then lists the “Additional Terms and Conditions” of that agreement and paragraph 12 of the “Additional Terms” states that “[e]xecution of the trusteeship agreement with respect to the Pilot Plan will occur only after the conclusion of the currently pending Pilot Plan litigation resulting in plan termination.”  URPBPA is appealing this Court’s ruling in the involuntary termination trial and the “Pilot Plan litigation” has not concluded.  As a result, United is obligated to continue maintaining both the qualified and non-qualified portions of the Pilot Plan until URPBPA has exhausted its appellate rights.

In addition, section 4(c) of Letter Agreement 05-01 between ALPA and United states that the “A Plan shall remain in full force and effect unless (i) the bankruptcy court issues an order declaring that the Company has met the requirements for plan termination under 29 U.S.C. § 1341(c)(2)(B)(ii)…” (Exhibit G, Letter Agreement 05-01 p. 2).  This Court has not entered an order declaring that United has met the requirements of § 1341(c)(2)(B)(ii).  As a result, even if the qualified portion of the Pilot Plan has been properly terminated by the PBGC, United should still be required to comply with § 4(c) of Letter Agreement 05-01 to the fullest extent possible and, because the PBGC takes no interest in or position with respect to the non-qualified portion of the Pilot Plan, United should do this by continuing to pay non-qualified pension benefits at the same rate at which such benefits have been paid throughout these Chapter 11 proceedings.  The fact that United has not done anything in connection with this bankruptcy to strip retired pilots of their contractually-vested right to receive non-qualified pension benefits, and the “full force and effect” provision of the ALPA agreement, demonstrate that United should be compelled to continue paying non-qualified pension benefits.

III.       Argument

            This Court should enter an order staying the effectiveness and enforceability of the Court’s October 26, 2005 termination order because terminating the Pilot Plan now is inconsistent with the “Additional Terms and Conditions” attached to the PBGC-United agreement.  Additionally, the payment of non-qualified pension benefits to retired pilots should continue because (1) United is still obligated to do so under the terms of Letter Agreement 05-01 and (2) because United has not terminated the contractual rights of its retired pilots to receive non-qualified pension benefits.  A stay order is appropriate and consistent with this Court’s prior orders and also with Bankruptcy Rule 8005.

            A.        The Additional Terms And Conditions Attached To The Order

                        Approving The PBGC-United Agreement Reflects That A Termination

Agreement Is The Agreed-Upon Format For Termination And

That No Termination Agreement Should be Entered Into Until The

Litigation Is Concluded

 

            Paragraph 4c of the PBGC-United agreement, approved by the Court, provides that the agreed-upon format for any termination of the Pilot Plan would be via a “termination agreement” with PBGC.  (see Exhibit H).  United, itself, recognized that termination would occur via a termination agreement with PBGC when United moved this Court to allow it and PBGC to enter into a termination agreement based on United’s belief that the Court had orally ruled on September 27, 2005 in favor of the PBGC in its termination action (See emergency motion for authority to enter into trusteeship agreement with PBGC to terminate pilot plan attached as “Exhibit I”).

Paragraph 12 of the PBGC-United Agreement states that the trusteeship agreement between United and the PBGC will be executed only after the “conclusion of the currently pending Pilot Plan involuntary termination litigation…”  In other words, the Pilot Plan is not to terminate until the involuntary termination litigation is fully litigated and, because both URPBPA and ALPA will appeal the Court’s October 26, 2005 order, this litigation has not reached its conclusion.  As a result, if this Court enters an order staying the effectiveness and enforceability of the October 26, 2005 order, the stay order will be consistent with the prior order of this Court and the terms of the PBGC-United Agreement.

            B.        URPBPA And The Retired Pilots Represented By URPBPA Also Satisfy

                        The Test Under Bankruptcy Rule 8005 For The Entry Of A Stay Order

            URPBPA and the retired pilots are also entitled to a stay of this Court’s October 26, 2005 order because they satisfy the standard for a stay set forth under Bankruptcy Rule 8005.  URPBPA’s appeal of the Court’s decision to order the termination of the Pilot Plan has a strong likelihood of success and the retired pilots will be obviously harmed if their pension benefits are reduced.  Furthermore, the entry of the stay order will have no substantial effect on third parties and, in fact, the entry of the stay order will serve the public interest.

                        1.         URPBPA’s Appeal Has A Likelihood of Success

            A party seeking a Rule 8005 stay order must show some likelihood of success on the merits.  Even in cases where an appellant’s chance of success on appeal are “less than compelling” and present no more than “an arguable case for reversing the Bankruptcy Court’s decision,” a stay should be entered when the appealing party makes a strong showing of irreparable harm.  Moody v. Amoco Oil Co., 31 B.R. 224, 225-26 (W.D.Wis. 1983).  The “likelihood of success” prong of the test should also be relaxed when relatively novel issues of law are involved.  See In re Mader, 100 B.R. 989, 990-91 (N.D. Ill. 1989). 

            URPBPA satisfies the first criteria of the test for a discretionary stay.  As this Court knows, the interpretation and application of § 1342(c) in the context of an involuntary termination trial is a matter of first impression and, as a result, the “success on the merits” criteria for the stay requested by URPBPA should be relaxed.  The entry of a stay order will preserve the status quo while the District Court and, perhaps, the Seventh Circuit Court of Appeals review the judgment entered in this case.

            There is also a strong possibility that it will obtain a reversal of this Court’s judgment on appeal.  At trial, the PBGC was required to prove every essential element of its case by a preponderance of the evidence.  Unsupported assertions or speculative statements regarding whether the Pilot Plan was likely to terminate, without any actual proof that United cannot afford to maintain the plan, is not proof.  A party who is responsible for proving an issue by the preponderance of the evidence cannot satisfy its burden of proof with unsupported speculation.  Halperin v. Department of the Air Force, 887 F.2d 1095 (table), 1989 WL 107700, * 5-7 (Fed. Cir. 1989).  See also Oiness v. Walgreen Co., 88 F.3d 1025, 1031 (Fed. Cir. 1996); Bryant v. St. Helena Parish School Board, 561 F. Supp. 239 (M.D.La. 1983) (“suspicions are insufficient, however, to amount to proof by a preponderance of the evidence”). 

            Despite the PBGC’s failure to prove that United was financially unable to continue the Pilot Plan so as to create an unreasonable increase in liability for PBGC, the Court entered a judgment in favor of the PBGC.  In the final paragraph of the Court’s memorandum of decision, the Court admitted that there were no witnesses at trial who testified regarding whether it was likely that the Pilot Plan would terminate and ignored the Kramer report, where the PBGC’s own expert showed that United could afford the Pilot Plan.  The PBGC did not admit into evidence a single document that demonstrated that it was likely that the Pilot Plan would terminate.  Yet, the Court ruled that the PBGC satisfied its burden of proof regarding the likelihood of plan termination because the “PBGC’s administrative record reflected United’s repeated statements in this case that termination of all of its defined benefit pension plans would be necessary for it to reorganize successfully, and United’s agreements with ALPA and the PBGC contemplated such a termination” (Exhibit E, p. 9).

            An employer’s self-serving statements regarding its inability to pay to maintain a defined benefit plan is not evidence that a defined benefit plan is, in fact, unaffordable and likely to terminate.  The fact that a debtor has entered into agreements which show that the debtor wants to terminate a pension plan is not proof that a plan is likely to terminate when an interested party is ready, willing and able to defend against the debtor’s efforts to terminate the plan.[1] 

URPBPA respectfully asserts that it is likely that an appellate court will reverse this Court’s ruling and rule that the PBGC failed to present any evidence regarding a critical issue it was required to prove at trial.

                        2.         United’s Retired Pilots Will Be Exposed To

                                    Irreparable Harm If The Stay Order Is Not Entered

 

            The retired pilots will suffer obvious and irreparable harm if their pension benefits are not paid on a timely basis.  The expert report of Thomas Levy, URPBPA’s expert, which was admitted into evidence as URPBPA exhibit BB, demonstrates that 60% of the nearly 6,000 retired pilots will lose between 30-60% of their pension benefits if the pension plan is terminated.  Accordingly, United’s retired pilots will suffer a devastating financial impact in dealing with their monthly financial obligations.

                        3.         Other Parties Will Not Be Harmed By The Stay Order

                                    And The Public Interest Will be Served

 

URPBPA will seek to have the appeal of this Court’s October 26, 2005 order resolved as quickly as possible so that this appeal does not harm any other party involved in these proceedings.  The entry of a stay order makes sense here because it does nothing more than preserve the status quo.  United has been maintaining the Pilot Plan throughout these proceedings and no party will be harmed if United continues to do so for another month or two while URPBPA’s appeal is being resolved.  The lack of harm to United is especially apparent as United has already agreed that a trusteeship to the PBGC of the Pilot Plan would not take place until the litigation is concluded.  Given the terrible financial consequences the retired pilots will immediately suffer if termination is allowed, the public interest would be served by allowing a stay and continuing the pension payments until the appeal is resolved.

            C.        The Order Entered Should Also Require United To

                        Continue Paying Non-Qualified Pension Benefits

            Alternatively, this Court should enter an order requiring United to at least continue paying non-qualified pension benefits to its retired pilots.  This Court’s prior order approving Letter Agreement 05-01 requires United to continue paying non-qualified pension benefits.  This Court has also twice enforced United’s obligation to pay non-qualified pension benefits.  Both times, the Court ruled that Letter Agreement 05-01’s “full force and effect” provision requires United to continue paying non-qualified pension benefits.  Even though the PBGC may have brought about the involuntary termination of the Pilot Plan, the PBGC’s proceedings did not have anything to do with the non-qualified portion of the Pilot Plan and United has not obtained from this Court, as required by Letter Agreement 05-01, an “order declaring that the Company has met the requirements for plan termination under 29 U.S.C. § 1341(c)(2)(B)(ii)…” (see Exhibit G, p. 2).  As a result, United should be ordered, once again, to continue paying non-qualified pension benefits as it is required to do under Letter Agreement 05-01.

            WHEREFORE, the United Retired Pilots Benefit Protection Association and Roger D. Hall, Dennis D. Dillon, Gerard Terstiege, Eugene M. Cummings, Raymond P. Fink, James M. Krasno and William L. Rutherford respectfully request that the Court enter an order


staying the enforcement and effectiveness of the October 26, 2005 judgment order entered by this Court. 

            Date:  November 2, 2005

                                                                        UNITED RETIRED PILOTS BENEFIT

                                                                        PROTECTION ASSOCIATION, ROGER D.                                                                                 HALL, DENNIS D. DILLON, GERARD                                                                                       TERSTIEGE, EUGENE M. CUMMINGS,                                                                                      RAYMOND P. FINK, JAMES M. KRASNO and                                                                           WILLIAM L. RUTHERFORD,

 

 

 

                                                                        By:      _________________________________

                                                                                    One of Their Attorneys

 

Jack J. Carriglio                                                                                                          

Eric E. Newman                                                                     

Meckler Bulger & Tilson L.L.P.                                            

123 North Wacker Drive, Suite 1800                        

Chicago, Illinois 60606                                              

(312) 474-7900 (phone)                                             

(312) 474-7898 (fax)                                                  

 

Frank Cummings

LeBoeuf, Lamb, Greene & MacRae, L.L.P.

1875 Connecticut Avenue, NW

Washington, DC 20009-5728

(202) 986-8000 (phone)

(202) 986-8102 (fax)

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[1]               Both of the referenced agreements were entered into after the December 30, 2004 termination date requested by PBGC.