"Since the U.S. Supreme Court's 2011 decision in Cigna Corp. v. Amara, ... the clear trend [is now] to allow plaintiffs to pursue various alternative forms of equitable relief side-by-side with a claim for plan benefits.... While the scope and extent of the discovery that may be conducted in benefits claims litigation under Section 502(a)(1)(B) is strictly limited, that is often not so in cases involving claims under Section 502(a)(3). Discovery and depositions are frequently one of the most, if not the most, time-consuming and costly aspects of litigation. Thus, the evolution in the law has a real world impact on the parties to ERISA litigation. Cases are, on the whole, taking longer to resolve and becoming more expensive to defend."