International Paper - PLANSPONSOR.com

Case 3:06-cv-00703-DRH-CJP Document 2 Filed 09/11/2006 Page 46 of 52K. To inform themselves of trends, developments, practices, and policies in theretirement, financial investment and securities industry which affect the Plans;and to remain aware and knowledgeable of such trends, practices and policies onan ongoing basis;L. To communicate with Plan participants and beneficiaries regarding the Planshonestly, clearly and accurately;M. To affirmatively and without request provide the Plans’ participants andbeneficiaries with honest, accurate and complete information they need tounderstand their investments in the Plans; the management, risk, potential returnsof such investments, and the fees and expenses incurred in connection with thoseinvestments;N. Upon request, to provide further information to the Plans’ participants andbeneficiaries regarding the operation and administration of the Plans and theexpenses incurred in doing so; andO. To provide honest, accurate and complete information to the Plans’participants and beneficiaries regarding the costs associated with their variousinvestment choices and directions.189. As set forth in detail above, Defendants breached their fiduciary obligationsto the Plans, the Plans’ participants and beneficiaries and the Class by, among other conduct tobe proven at trial:A. Causing the Plans to enter into agreements with service providers underwhich the Plans pay/paid – directly or indirectly -- fees and expenses that were,46