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Case 3:06-cv-00703-DRH-CJP Document 2 Filed 09/11/2006 Page 7 of 5239. Defendant is IPC’s Director—Corporate Finance and a member of the Committee.Plaintiffs have not, despite investigation, determined the names of the individual holding thisposition. Plaintiffs will amend and supplement this complaint when they obtain this information.40. Defendant is IPC’s Senior Manager—Communications 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.41. Defendant Mark Lehman is an officer and/or employee of IPC and is theindividual designated by IPC to sign documents as Plan Administrator for both the Hourly andSalaried Plans.42. Defendant Bob Hunkeler is IPC’s Vice President—Investments and is theInvestment Officer of both the Salaried and Hourly Plan.43. Defendant Jerome N. Carter is IPC’s Senior Vice President–Human Resourcesand, according to the Plans’ Summary Plan Descriptions, is the Administrator of the Plan and anamed fiduciary of the Plan.Jurisdiction and Venue:44. Plaintiffs bring this action pursuant to ERISA §§ 502(a)(2) & (3), 29 U.S.C. §1132(a)(2) & (3), which provides that participants may pursue civil actions on behalf of the Plansto remedy breaches of fiduciary duty as set forth in ERISA § 409, 29 U.S.C. § 1109, and/or toobtain other appropriate equitable relief. This Court has federal question subject matterjurisdiction pursuant to 28 U.S.C. § 1331 and 29 U.S.C. § 1132(e)(1)(2).7