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am familiar with the proceedings herein, and em authorized Dy the USwA Co file this Proof of Claim on behalf of the USwA and retired former barga fining-unit employees of the Debtors ("Retirees"). 2. Pursuant to collective bargaining agreements with the USWA, the Debtors have provided certain health and medical benefits far Retirees and their dependents. 7. One of the benefits prov idetl to certain eligible Retirees is a prescription drug program. This. program is paid. • for entirely by the eligible Retirees threugti~deductions by the Debtors from the eligible Retirees' monthly pension payments ("Retiree Contributions"). 4. This is an unliquidated claim, pursuant to paragraph 61 of the Joint Plan of Recrganization, for any indemnification obligation of the Debtors to their officers, directors, and responsible management personnel, for amounts which are and/or may become due related in any way to Retiree Contributions through the Effective Date of the Joint Plan of Reorganization, as well as amounts arising from any fiduciary or other obligations, or breaches thereof, related to such Retiree Contributions, by the Debtors, its officers, directors, agents, and/or responsible employees. The Debtor is in possession of the • relevant collective bargaining agreements and related documents. 5. As a matter of law, the USWA is authorized to file claims for and on behalf of itself and Retirees for amounts and/or benefits which may be due and owing to such Retirees. 6. Claimant demands priority to the extent provided by 11 U.S.C. g§50~(a)(1), 1114, and as monies hel^ in trust. Dated: March 2, 1997 Ann E. O'Shea, Esq. COHEN, WEI55 and SIMON 770 West 42nd Street New York, New York 10076 (212) 563-4100 Attorneys for United Steelworkers of America P ltv for n sentine fraudulent clai Fine of not more than 55,000 or Smptlsonment for not more than five years or both. Title 18 U.S.C. §152. 2