MFN Partners, LP, et al. v. New York State Teamsters Conference and Retirement Fund, et al.
This document is an application for an extension of time to file a petition for a writ of certiorari, not a petition for certiorari itself. It does not contain a "Question(s) Presented" section in the traditional sense.
However, the document does present two legal questions in paragraph 2, which are the substantive issues the petitioners intend to raise:
Whether the Pension Benefit Guaranty Corporation (PBGC) can—through the auspices of imposing "reasonable conditions" on multiemployer pension plans (MEPPs) under 29 U.S.C. § 1432(m)(1)—direct MEPPs to exclude certain plan assets from the unfunded-vested-benefits formula in 29 U.S.C. § 1393(c) when calculating an employer's withdrawal liability, even though that statutory formula expressly includes plan assets as an input.
Whether MEPPs can calculate a withdrawing employer's allocable unfunded vested benefits and annual withdrawal-liability payments through methods that deviate from statutory requirements without obtaining the PBGC's approval.
Whether the Pension Benefit Guaranty Corporation can impose 'reasonable conditions' on multiemployer pension plans that deviate from the express statutory formula for calculating withdrawal liability under ERISA