"The court noted that Ninth Circuit precedent calls for a narrow interpretation of ERISA Section 104 as it applies to plan document disclosure requests, explaining that not all contracts and other internal documentation dealing with plan administration are required to be disclosed.... [T]he ruling demonstrates that courts have wide latitude in awarding penalties in these situations, and that a plan's good faith response in accordance with relief granted due to a pandemic or other disaster can prove to be timely and penalty-averting behavior." [Zavislak v. Netflix, Inc., No. 24-4156 (9th Cir. Sep. 24, 2025; unpub.)]  MORE >>