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The 'Make Whole' Defense to Reimbursement: Rule of Interpretation or General Equitable Defense?
Health Plan Law 
Aug. 17, 2007
"Mark Abramson, of Robison, Curphey & O'Connell, submitted an interesting new ERISA subrogation decision from the Northern District of Ohio for publication on this site. In this decision, the district court held that the plan could enforce a reimbursement provision against a plan participant after a recovery by the participant in a personal injury action."
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