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Statute of Limitations for Contract Actions Applied to an ERISA Appeal of a Denial of Benefits
Melville Johnson, P.C. 
[Guidance Overview] June 15, 2008
Excerpt: [T]he District Court held that while Pettaway's claims accrued upon denial in August 2004, the limitations period was tolled until September, 2005 when the internal appeal process was concluded. Thus, the lawsuit was timely filed and the motion to dismiss was denied.
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