38 pages. Excerpt: This case presents a critically important issue - whether minimum contributions, required under ERISA section 302, 29 U.S.C. § 1082, constitute an administrative expense and are an actual and necessary cost of operating the debtor's business in a Chapter 11 bankruptcy proceeding, where the debtor in possession has continued and not terminated the affected ERISA plan. The Secretary respectfully submits this amicus brief to aid and assist the Court.