"Hartford both administers and funds the plan. Under [Metropolitan Life Ins. Co. v. Glenn, 554 U.S. 105 (2008)], such dual obligations may create a structural conflict of interest. Furthermore, without a convincing explanation, the altered claim form suggests a procedural irregularity. Although plausible, Hartford's explanation regarding the alteration is speculative ... [T]he potential structural conflict of interest coupled with the procedural irregularity of the altered form warrant further discovery. However, even where discovery regarding an alleged conflict of interest is appropriate, courts generally place narrow restrictions on the scope of discovery permitted. Plaintiff's requests are expansive and must be narrowed to target information actually relevant to the alleged conflicts." [Greene v. Hartford, No. 13-6033 (E.D. Penn. Feb. 6, 2015)]  MORE >>