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1. I am the Director, Industrial Relations of CFiI <br />Steel Corporation ("CFSI"). I make this Affidavit based on faci:s <br />personally knovn to me. <br />2. None of the Post-Petition Black Lung Benefit <br />Beneficiaires were employed by CFiI at the Bokoshe Mine. <br />3. Many, although not all of the Post-Petition Black <br />Lung Benefit Beneficiaries are receiving pension benefits nt th:Ls <br />time. <br />4. The Post-Petition Black Lung Benefit Beneficiaries <br />who are or were members of the International Union, United Mine <br />Workers of America (the "UMWA") may be qualified to receive ar <br />may be receiving pension benefits pursuant to the "UMWA 1950 <br />Pension Plan and Trust" or ^UMWA 1974 Pension Plan and Trust" and <br />non-pension benefits under the "UAtWA 1950 Benefit Plan and Trust" <br />or the "UMWA 1974 Benefit Plan and Trust." <br />5. All of the UMWA Plans and Trusts are industry-vic9e <br />plans and trusts in which coal mine operators and miners <br />participated. <br />6. All UMWA members are potentially eligible to <br />receive pension or non-pension benefits under the DMWA plans lrom <br />the UMWA Trusts. The UMWA members need not have been employed by <br />CF6I at all or for any minimum number of years to receive pension <br />or non-pension benefits under the UMWA Plans from the UMWA <br />Trusts. <br />2 <br /> <br />