"The Fifth Circuit held that [ERISA's] catch-all provision should be interpreted narrowly so as to apply only to formal legal documents that govern a plan.... In adopting this approach, the Fifth Circuit generally follows the Second, Fourth, Seventh, and Eight Circuits ... In contrast, the Sixth Circuit favors disclosure where it would help participants understand their rights. The Ninth Circuit has found that documents should be provided to the extent they provide individual participants with information about the plan or benefits." [Murphy v. Verizon Communications, Inc., No. 13-11117 (5th Cir. Oct. 14, 2014)]