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Text of Eleventh Circuit Opinion: Definition of Plan Term Found Only in Extrinsic Documents Does Not Render Plan Document Ambiguous (PDF)
U.S. Court of Appeals for the Eleventh Circuit 
Oct. 17, 2014
"[B]ecause the Plan defines 'Normal Retirement Date' in reference to Meadowcraft's 'published or accepted personnel practices,' it was necessary for the district court to examine extrinsic evidence of Meadowcraft's personnel practices to determine the Normal Retirement Date. This does not mean the contract was ambiguous. Courts routinely examine extrinsic evidence to determine the meaning of contract terms even while holding that the contract is unambiguous." [Snow v. Boston Mutual Life Ins. Co., No. 13-15067 (11th Cir. Oct. 16, 2014)]
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