"[1] Whether a provider has sufficiently pleaded the existence of a valid assignment clause to withstand a Motion to Dismiss in light of recent Third Circuit precedent.... [2] Whether Plaintiff's disability related to COVID-19 fell under a pre-existing condition exclusion in the long-term disability policy.... [3] Whether the insurance company's letter communicated rational reasons for its decision to deny a long-term disability claim.... [4] Did Plaintiff's complaint adequately plead the existence of a federal question such that defendant's notice of removal was untimely? ... [5] Whether the insurance company satisfied its fiduciary duty as mandated under ERISA to consider Plaintiff's claim fully and provide specific reasons for denial."

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