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MetLife v. Glenn Decision Wedges Open Discovery on Use of Outside Consultants
Health Plan Law 
[Guidance Overview] Aug. 5, 2008
Excerpt: It was just a matter of time before we saw a case where the district court judge took a fresh view of discovery limitations in view of the Supreme Court's decision in MetLife v. Glenn. In Hogan-Cross, Judge Kaplan rejected MetLife's position that discovery should be limited to the 'administrative' record simply because the policy language contained a discretionary clause. The opinion will likely receive ample use in ERISA discovery disputes on a wide range of issues.
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