"Unum delayed pursuing the motion to transfer for seven months, waiting until one week before the close discovery and three weeks before the deadline for dispositive motions to file it. The impetus for doing so was the discovery of medical records outside the administrative record that favor Plaintiff's case. These extra-record documents are admissible in the 11th Circuit (Florida) but not in the 10th Circuit (Utah). The court found this legal difference was relevant in illuminating the parties' motivations." [Williams v. Unum Life Ins. Co. of Am., No. 24-24113 (S.D. Fla. June 5, 2025)]  MORE >>