"[T]he 9th Circuit [recently] held that the burden of proof shifts to the employer ... when a claimant has made a prima facie case that he is entitled to a benefit but lacks access to key information that the [employer] controls.... [R]ecords for retirement plans should be kept until all benefits have been paid, the trust has been dissolved and sufficient time has passed such that the plan will not be the subject of an audit." [Estate of Barton v. ADT Security Serv. Pension Plan, No. 13-56379 (9th Cir. Apr. 21, 2016)]  MORE >>