"[T]he Court held that 'a district court may consider evidence outside of the administrative record ... when such evidence is necessary to adequately assess the Booth factors and the evidence was known to the plan administrator when it rendered its benefits determination'.... [The] Court suggested a dramatically increased discovery burden, requiring the administrator to make exhaustive searches into past decisions -- something for which the administrator would not necessarily have had any reason to search in reviewing the claimant's benefit claim, as every claimant's case is based upon its own unique facts. " [Helton v. AT&T, Inc. Pension Benefit Plan, 2013 U.S. App. LEXIS 4575 (4th Cir. Mar. 6, 2013)]  MORE >>