International Paper - PLANSPONSOR.com

Case 3:06-cv-00703-DRH-CJP Document 2 Filed 09/11/2006 Page 6 of 5231. IPC is the Sponsor of the Plans pursuant to ERISA § 3(16)(B).32. Defendant Thomas A. Kliman is an officer or employee of IPC and the individualdesignated by IPC to sign documents on behalf of IPC as Plans’ Sponsor.33. Defendant International Paper 401(k) Committee (the “Committee”) is the namedfiduciary and Administrator of the Plans.34. In Article 14 of both the International Paper Salaried Savings Plan, Amended andRestated as of January 1, 2006 (the “Salaried Plan Document”) and the International PaperHourly Savings Plan, Amended and Restated as of January 1, 2006 (the “Hourly PlanDocument”), IPC appoints the Committee and specifies its members by their title/position in theCompany.35. Under Article 14 of both Plan Documents, the Committee is comprised of fiveIPC officers and directors: (1) Manager—Salaried Compensation; (2) Director—CorporateFinance; (3) Vice President—Corporate Marketing; (4) Senior Manager—Communications; and(5) Vice President & CTO—Information Technology.36. Defendant Ethel A. Scully is IPC’s Vice President—Corporate Marketing and amember of the Committee.37. Defendant John N. Balboni is IPC’s Vice President & CTO—InformationTechnology and a member of the Committee.38. Defendant is IPC’s Manager—Salaried Compensation and a member of theCommittee. Plaintiffs have not, despite investigation, determined the names of the individualholding this position. Plaintiffs will amend and supplement this complaint when they obtain thisinformation.6