Mealey's (December 12, 2018, 11:10 AM EST) -- SAN FRANCISCO — A district court did not err in finding that a multiemployer pension plan correctly applied a prior partial withdrawal credit before applying a credit under the debt forgiveness provision, as outlined in the Multiemployer Pension Plan Amendments Act (MPPAA), after a union withdrew its participation in the retirement fund, the Ninth Circuit Court of Appeals said Dec. 7 (GCIU-Employer Retirement Fund, et al. v. Quad/Graphics Inc., No. 17-55667, 9th Cir., 2018 U.S. App. LEXIS 34489)....