July 2, 2004. Excerpt: "[I]t appears that there is a separate trust with a direct legal obligation to pay the benefits due under the Plan. However, contributions do not appear to bear any relationship to the Plan's accruing liability and the administrator has not exercised its power under the Trust document to establish a rate of contribution ... [T]he essential nature of the Trust [is] as a mere pass-through vehicle for the employer's payment of ordinary vacation wages[.]"