"[T]he DOL regulations governing the electronic distribution of SPDs.... limit this option to participants who can effectively access electronic documents wherever the participant is reasonably expected to perform his or her duties, and for whom access to the employer's electronic information system is a regular part of those duties. While that may have been true of this employee before she became disabled, it was not the case when she actually needed the SPD. This was after she had terminated her employment (due to the disability), thereby losing access to the intranet. As a result, she could not access the SPD during the 12-month period in which she was required to submit proof of her disability." [Thomas v. CIGNA Group Ins., No. 09-CV-5029 (E.D.N.Y. Mar. 2, 2015)]