Happy Tuesday! There were a few notable appellate decisions this past week. The First Circuit held that a plan administrator’s failure to inform a disability claimant of the plan’s time limit for filing suit rendered it inapplicable as a bar against the claimant’s lawsuit. The Seventh Circuit held that a pension plan maintained by a non-profit corporation affiliated with a church did not qualify as an ERISA-exempt church plan. And, in a separate decision, the Seventh Circuit also held that a pension plan properly calculated retirement benefits when it offset the amount of normal retirement benefits a participant would have received had he not retired early and received a lower monthly benefit amount.
There were also a few notable district court decisions, including a matter out of the Western District of Wisconsin, where the court found that a disability plan administrator abused its discretion by creating a “moving target” as to the reasons for denial. Speaking of moving targets, ERISA Watch has a new distribution date: Tuesdays!
Your reliable source for summaries of recent ERISA decisions
Below is Roberts Disability Law summary of this past week’s notable ERISA decisions.
A plan administrator’s failure to inform a claimant of the time limit for filing suit renders the contractual limitations period inapplicable. Santana-Diaz v. Metro. Life Ins. Co., No. 15-1273, __F.3d___, 2016 WL 963830 (1st Cir. Mar. 14, 2016) (Before THOMPSON, HAWKINS,* and BARRON, Circuit Judges). Plaintiff-Appellant challenged the district court’s dismissal of his suit for long term disability benefits as time-barred, because the plan administrator, Appellee Metropolitan Life Insurance Company (“MetLife”), failed to include the time period for filing suit in its denial of benefits letter. The Plan contained a three-year limitations period that provided, in relevant part, that “[n]o legal action of any kind may be filed … more than three years after proof of Disability must be filed.” Under this provision, Plaintiff’s proof of disability had been February 17, 2009, and according to MetLife, the time period for filing suit expired three years thereafter. MetLife terminated Plaintiff’s claim on November 24, 2010 and issued a final denial on August 19, 2011. Neither letter informed Plaintiff of the time limit for filing suit; Plaintiff filed suit on August 18, 2013. The First Circuit held that ERISA’s regulation, 29 C.F.R. § 2560.503-1(g)(1)(iv), requires a plan administrator in its denial of benefits letter to inform a claimant of not only his or her right to bring a civil action, but also the plan-imposed time limit for doing so. The plan administrator’s failure to do so is per se prejudicial to the claimant. The court found that because MetLife violated this requirement, the limitations period in this case was rendered inapplicable, and Plaintiff’s suit was therefore timely filed. Because the court found that MetLife violated the regulation, it did not decide when the limitations period would have begun to run (i.e., February 17, 2009 versus November 24, 2010 versus August 19, 2011). The court reversed and remanded the decision of the district court.
Pension plan maintained by non-profit corporation affiliated with two Christian denominations is not an ERISA-exempt church plan. Stapleton v. Advocate Health Care Network, No. 15-1368, __F.3d___, 2016 WL 1055784 (7th Cir. Mar. 17, 2016) (Before BAUER, KANNE, and ROVNER, Circuit Judges). The Seventh Circuit considered whether a pension plan established by a church-affiliated organization, such as a hospital, is a “church plan” exempt from ERISA’s requirements. Here, Defendant Advocate maintains a non-contributory, defined-benefit pension plan that covers substantially all of its employees. Advocate is not a church, nor was its predecessor. Advocate was formed in 1995 as a 501(c)(3) non-profit corporation from a merger between two health systems-Lutheran General HealthSystem and Evangelical Health Systems. The court agreed with the district court in finding that the pension plan at issue is not a church plan that would be exempt from ERISA. Specifically, a plan cannot qualify as a church plan merely by being maintained by a church-affiliated organization because then the “established by a church” requirement of 29 U.S.C. § 1002(33)(A) would become meaningless. The court concluded that the text of ERISA is not ambiguous, but regardless, the legislative record does not suggest an intent to allow a church-affiliated corporation to claim the exemption for a plan unless the church itself has established the plan, as required by the original definition of a church plan in subsection (33)(A) of ERISA. The court also declined to give deference to contrary IRS private letter rulings that conflict with the plain language of the statute and fail to consider the relationship between the definitions of a church plan in subsections (33)(A) and (33)(C)(ii). Lastly, the court rejected Advocate’s constitutional claim under the First Amendment. The court affirmed the opinion of the district court.
Amount of early retirement benefit is proper offset under retirement plan. Cocker v. Terminal R.R. Ass’n of St. Louis Pension Plan For Nonschedule Employees, No. 15-2690, __F.3d___, 2016 WL 1055839 (7th Cir. Mar. 16, 2016) (Before POSNER, FLAUM, and EASTERBROOK, Circuit Judges). At issue in this case is the proper benefit payable under a retirement plan, which provides that “the retirement income benefit payable under this Plan shall be offset by the amount of retirement income payable under any other defined benefit plan … to the extent that the benefit under such other plan or plans is based on Benefit Service taken into account in determining benefits under this Plan.” The Plan further provides that if “the benefit under such another plan is paid in a form other than the form of payment under this Plan, including without limitation a single lump sum cash payment made prior to retirement, the amount of such offset shall be the dollar amount per month of the benefit that would have been payable under such other plan in the form of a Single Life Annuity commencing on the Participant’s Normal Retirement Date.” The parties dispute the meaning of “payable,” since Plaintiff took an early retirement from the Union Pacific Plan and received a monthly benefit of $1,022.94 rather than the $2,311.73 that he would have received had he waited until normal retirement age to retire. The district court found in favor of Plaintiff in that the Plan should have reduced his benefit by the lower amount that he received. The Seventh Circuit found that the two dollar figures are actuarially identical, in the sense that the present value of the two streams of money is the same because the smaller monthly benefit is received for 111 months longer than the larger one. The monthly offset required by the Plan is the amount payable under the prior employer’s plan and $2,311.73 was the maximum amount payable to Plaintiff per month under the Union Pacific Plan. Further, Plaintiff lost nothing by choosing to receive only $1,022.94. The court reversed the judgment with instructions to dismiss the suit with prejudice.
Select Slip Copy & Not Reported Decisions
Following Rule 68 offer, court grants motion for attorneys’ fees in part. F. v. Blue Shield of California, No. 09-CV-2037-PJH, 2016 WL 1059459 (N.D. Cal. Mar. 17, 2016) (Judge Phyllis J. Hamilton). In this putative class action involving the denial of residential treatment, and following Blue Shield’s stipulation to entry of judgment in favor of Plaintiffs in the amount of $79,954, Plaintiff moved for summary judgment on the issue of damages, costs, and attorneys’ fees. The court granted the motion as to the amount of damages of $79,954; denied requested costs in the amount of $18,196, but without prejudice to submitting the costs post-judgment in a proper cost bill (except for costs incurred after Blue Shield made its Rule 68 offer); denied prejudgment interest at a rate of 15% but granted as to the request for prejudgment interest and post-judgment interest at the statutory rate; and granted in part and denied in part as to the amount of the attorney’s fees. Plaintiff sought a total of $725,801.27 but the court awarded reduced fees of $339,298.07. The court awarded a San Francisco attorney in practice for 15 years the rate of $650/hour. The court declined to award the same rate to Utah attorneys who also worked on the case since it found that the customary billing rates in Utah are significantly lower. The court awarded rates of $450 and $340 for the Utah attorneys, both of whom have been in practice for 30 years or more.
Post-judgment attorneys’ fees denied to both parties. Brasley v. Fearless Farris Serv. Stations, Inc., No. 1:08-CV-00173-BLW, 2016 WL 1032785 (D. Idaho Mar. 14, 2016) (Judge B. Lynn Winmill). In this case, the court had awarded judgment in favor of Plaintiffs following a bench trial in 2010. The court then awarded $390,153.60 plus costs in the amount of $537.67. Six years later, Defendants finally complied with the Court’s Judgment in what the court described as “more frustrating than almost any other case I have dealt with in my nearly 30 years as a judge.” Both sides requested that the other pay for their attorneys’ fees but the court denied both motions. The court was required to appoint a Special Master to resolve the issue of compliance with the Court’s judgment, and that the Special Master ultimately recommended that the Qualified Plan be terminated and that Defendants pay Plaintiffs lump sum amounts – a concept neither party suggested or advocated. The court also denied Plaintiffs’ request to require Defendants to pay the mediator fees that they had agreed to split. However, the court ordered Defendant to pay the bill of the actuary who acted under the direction of the Special Master.
Breach of Fiduciary Duty
For breach of fiduciary duty claim, oral misrepresentations can override the written SPDs’ unambiguous terms. Fulghum v. Embarq Corp., No. 07-2602-EFM, 2016 WL 1060207 (D. Kan. Mar. 15, 2016) (Judge Eric F. Melgren). In this matter, Plaintiffs, on behalf of themselves and a certified class, alleged that Defendants violated ERISA by eliminating retirees’ medical and life insurance benefits. On Defendants’ motion for summary judgment on two of the seventeen Plaintiffs’ breach of fiduciary duty claim, the court found that Defendants had an affirmative duty to provide complete information regarding Plaintiffs’ retiree benefits based on information they knew or should have known and that the Reservation of Rights clauses in the SPDs do not necessarily shield Defendants from breach of fiduciary duty liability if they made oral material misrepresentations. The court found that Plaintiffs can rely upon oral misrepresentations. The court further fond that there appear to be questions of fact as to the content of the actual oral statements and whether Defendants made misrepresentations is a disputed fact precluding summary judgment.
Counterclaim for recoupment of benefits paid under a reservation of rights not subject to dismissal. Steiner v. Cigna Life Ins. Co. of New York, No. 15-CV-0391 (KM), 2016 WL 916687 (D.N.J. Mar. 10, 2016) (Judge Kevin McNulty). Plaintiff brought a Section 1132(a)(1)(B) claim alleging that Defendant wrongfully determined, after eleven years of payments, that Plaintiff was no longer disabled. After CLICNY denied benefits, Plaintiff appealed. CLICNY agreed to continue payment of benefits while Plaintiff underwent an independent medical exam. In response to Plaintiff’s lawsuit, CLICNY filed a counterclaim alleging that it paid the interim benefits pursuant to a reservation of rights and that it could recoup these interim benefits in the event the appeal was denied. The Counterclaim asserts that if the court determines that Plaintiff is not entitled to LTD benefits after they were terminated, CLICNY is entitled to repayment and/or restitution of the amount of LTD benefits that CLICNY paid to him under a reservation of rights, plus interest. Plaintiff contented that any reservation of rights must appear in the Plan documents, but the court found this argument too broad. The court found that the counterclaim presents, at the very least, an issue of fact unsuitable for resolution without development of a record in discovery. The court denied Plaintiff’s motion to dismiss the counterclaim.
Insurer abused discretion in denying long term disability benefits; remand for further consideration of claim. Clark v. Cuna Mut. Long Term Disability Plan, No. 14-CV-412-WMC, 2016 WL 1060344 (W.D. Wis. Mar. 15, 2016). In this case, Plaintiff claimed disability based on the following medical conditions: lumbar radiculopathy, herniated nucleus pulposus (lumbar), degenerative disc disease, disc collapse, foraminal stenosis, chronic lower back pain, right-sided lower extremity pain, recurrent disc herniation at L5-S1, depression, and residual right nerve root tension and weakness in the right lower extremity. The court found that Defendants acted arbitrarily and capriciously in denying Plaintiff’s long term disability benefits and remanded to the administrator for further proceedings. The court found that Defendants’ use of Dr. Stewart Russell to conduct the review of their decision to terminate Plaintiff’s benefits, and again on the second voluntary appeal of that decision, did not violate ERISA’s regulations since Defendant did not retain the same doctor for both the adverse benefit determination and for the appeal of that decision. But, the court did find that Defendants acted arbitrarily and capriciously by failing to offer a reasoned explanation for rejecting medical opinions that Plaintiff was not capable of working and strong evidence supporting disability, including multiple failed surgeries, Plaintiff’s complaints of back pain, Plaintiff’s doctor’s assessment of his condition as continuing, and MRI findings. The court also found that Defendants created a “moving target” by discounting a July 2012 MRI because it did not demonstrate disability as of January 2012. On remand, the court instructed Defendants to consider whether the July 2012 MRI is likely to have reflected Plaintiff’s condition as of January 2012 in light of the continuity of evidence in his medical record at those two times.
Pension fund did not abuse its discretion in denying pension plan benefits. Finley v. Carpenters Pension Trust Fund for N. California, No. 213CV1132GEBEFBPS, 2016 WL 1060169 (E.D. Cal. Mar. 17, 2016) (Judge Edmund F. Brennan). In this matter involving the denial of disability pension plan benefits, Plaintiff challenged Defendants decision finding that he was not working in covered employment for certain periods of time, the result of which was to reduce the amount of his monthly disability benefits. Specifically, he challenged the denial of Future Service Eligibility (“FSE”) credits for several periods of time and he also challenged Defendants’ determination of the date of his eligibility for disability pension benefits. The court determined that Defendants reasonably interpreted the language of the pension plan in determining the effective date for Plaintiff’s disability pension and that he was not entitled to receive FSE credits during certain absences from work. With respect to which version of the Plan applies to Plaintiff’s claim, the court found that Plaintiff was not eligible to start receiving a disability pension until January 2009, which fell during the period governed by the 2007 version of the Plan. With respect to the date Plaintiff was eligible to receive disability pension benefits, the court found that Defendants reasonably concluded that Plaintiff was not eligible for benefits until after he was entitled to receive social security disability benefits. The Plan provides that disability benefits under the Plan “begin after you have been disabled for 6 full months and continue as long as you are eligible for Social Security Disability Benefits.” Lastly, with respect to FSE credits for the disputed periods of time, the court found that Plaintiff was not absent from covered employment due to a disability, as required by section 6.04 of the Plan, and he was not entitled to receive FSE credits. The court denied Plaintiff’s motion for summary judgment and granted the Pension Fund’s cross-motion for summary judgment.
Court permits discovery regarding disability reviews done by doctor employed by University Disability Consortium. Feltington v. Hartford Life Ins. Co., No. 14CV6616ADSAKT, 2016 WL 1056568 (E.D.N.Y. Mar. 15, 2016) (Judge A. Kathleen Tomlinson). In this matter involving a denial of long term disability benefits, Plaintiff moved to seek certain discovery beyond the administrative record. The court denied Plaintiff’s request for the court to order Hartford to produce a witness under Federal Rule of Civil Procedure 30(b)(6) to testify regarding Hartford’s handling of correspondence it received from Plaintiff after Hartford issued its decision on administrative appeal and closed Plaintiff’s file. Instead, the court ordered Hartford to produce responsive information regarding whether Hartford has an internal procedure for reopening or reconsidering closed claims, and if such a procedure exists, what that procedure is and whether that procedure was applied or followed with regard to Plaintiff’s claim. The court also denied Plaintiff’s request to depose the doctor retained by Hartford to review Plaintiff’s medical documentation on appeal since the court found that Plaintiff did not show that there is a reasonable chance that deposing the doctor will lead to admissible evidence which satisfies the good cause standard. However, the court did order Hartford to respond to an interrogatory with information regarding: (1) the number of times Hartford received a medical review of a long term disability claim from Dr. Neal Small of University Disability Consortium; and (2) the number of times Dr. Small found the claimant to be disabled.
Claim for unpaid wages is not preempted by ERISA. Bergen v. Tualatin Hills Swim Club, Inc., No. 3:16-CV-00052-HZ, 2016 WL 1064488 (D. Or. Mar. 16, 2016) (Judge Hernandez). Plaintiff alleged that Defendant violated Oregon law when it failed to pay him “all wages due and owing” by the end of the first business day after his discharge. Plaintiff’s representative “sent a written demand for payment of outstanding wages in accordance with ORS 652.150,” and included as “wages” unpaid retirement benefits for 2013 and 2014. Although Plaintiff’s attorney referred to ERISA-governed benefits to which Plaintiff was entitled in the written demand letter in order to articulate and quantify damages, the court found that this is an insufficient basis upon which to find complete preemption. Nowhere in the Complaint did Plaintiff state a claim for retirement benefits. The court concluded that nothing in the record suggests that Plaintiff could have proceeded under ERISA or that an ERISA-governed plan may grant what Plaintiff is asking for-past wages due and penalty wages, pursuant to Oregon state law obligations.
Medical Benefit Claims
Fund abused its discretion in denying payment for rehabilitative treatment for stroke patient. Soehnlen v. Fleet Owners Ins. Fund, No. 1:15 CV 1181, 2016 WL 930983 (N.D. Ohio Mar. 11, 2016) (Judge Patricia A. Gaughan). In this case, Plaintiff incurred significant medical expenses as a result of a debilitating stroke. Much of Plaintiff’s rehabilitative treatment was with Mentis Ohio, LLC, a neuro rehabilitation facility. The Fund’s third-party claims administrator denied payment for many of the services Plaintiff received at Mentis on the basis that maximum benefits were provided for the services. Plaintiff appealed to the Fund’s Trustees and they denied the claim for new reasons, including that Mentis is out-of-network and Mentis has engaged in fraudulent billing. Plaintiff filed a second appeal but the Fund did not respond in a timely manner. On Plaintiff’s motion for summary judgment, the court found that the Fund’s offer of indemnification made during court-ordered mediation did not make the case moot. The court believed that the offer should not have been disclosed because it came about in mediation. Regardless, the court found that the offer did not cover all of the claims at issue in the case. On the standard of review, the court found that SPD does grant discretionary authority to the Trustees so arbitrary and capricious review applies but that it does not apply to questions of law, such as whether the Fund’s procedure in denying the claim meets the requirements of ERISA Section 1133. The court also found that Plaintiff did exhaust administrative remedies since the Fund did not respond to Plaintiff’s second appeal within sixty days as required by the ERISA regulations and Plaintiff filed suit after the Fund’s decision was due. Plaintiff argued that the Fund did not substantially comply with Section 1133 because, at the second-tier review, the Trustees articulated different reasons for denying his claims than the third-party claims administrator articulated at the first-tier review. The court agreed that the Trustee’s denial did not substantially comply with the ERISA notice requirements. First, the Trustees offered two rationales for denying Plaintiff’s claims but did not cite to any specific plan provision. Second, the Trustees’ new rationale and their failure to acknowledge Plaintiff’s second appeal request effectively denied Plaintiff an opportunity to respond. The court found that the absence of reasoning in the record to support the Trustees’ decision was arbitrary and capricious. The court ordered a remand to Defendant as the remedy but found that Defendant forfeited its grandfathered status under the ACA and could not rely on its grandfathered status to deny Plaintiff’s claim.
Interference claim not subject to dismissal. Gipson v. Four Cty. Comprehensive Mental Health Ctr., Inc., No. 3:15CV360-PPS/CAN, 2016 WL 1059355 (N.D. Ind. Mar. 16, 2016) (Judge Philip P. Simon). Plaintiff filed a complaint alleging that her termination was an act of age discrimination, disability discrimination and interference with her rights under the Center’s health insurance plan. Plaintiff was terminated after her disabled son visited her at her workplace carrying a gun that he was licensed to carry. Defendant claimed that Plaintiff violated the No Weapon Policy by failing to report her son’s visit but Defendant did not terminate other employees who also did not report the incident. Plaintiff contended that she instructed her son to leave the building and did not violate the policy but also that her son has Crohn’s Disease, is a covered dependent under her employer-provided healthcare insurance, and requires costly medical care. Plaintiff’s supervisor was aware of these facts. The court found that Plaintiff’s complaint contains sufficient plainly-stated facts to support plausible claims that her termination was unlawfully based on her age, her son’s disability, and/or an effort to interfere with her continued coverage under the Center’s ERISA health insurance plan. The court held that the complaint is not subject to dismissal for failure to state claims upon which relief could be granted.
Statute of Limitations
Contractual limitations period bars late filed disability claim. Wilson v. Provident Life & Accident Ins. Co., No. CV 14-499-SDD-EWD, 2016 WL 1057036 (M.D. La. Mar. 14, 2016) (Judge Shelly D. Dick). Following the Supreme Court’s decision in Heimeshoff v. Hartford Life & Acc. Ins. Co., which held that “a participant and a plan may agree by contract to a particular limitations period, even one that starts to run before the cause of action accrues, as long as the period is reasonable,” the court found that a disability policy’s limitations period is not unreasonable nor exceeds the applicable statute of limitations. Plaintiff claimed to be disabled on October 13, 2008, and had he timely filed a claim at this time, under the terms of the Policy, his proof of loss would have been due no later than May 13, 2010. Plaintiff submitted proof of loss on April 22, 2013. The court found that Plaintiff had three years from May 13, 2010, or May 13, 2013, to file his lawsuit but did not do so until August 11, 2014. Notably, Provident did not issue a final decision on his claim until June 4, 2014. The court found that Plaintiff’s claim must be dismissed because his claim has prescribed under the terms of the Policy.
Settlement agreement does not preclude an assignee from enforcing its subrogation and reimbursement rights. Cont’l Ins. Co. v. Dawson, No. 15-10510, __Fed.Appx.___, 2016 WL 1055371 (5th Cir. Mar. 15, 2016) (Before KING, JOLLY, and PRADO, Circuit Judges). Continental Insurance Company, acting as an assignee, filed a lawsuit in federal district court to enforce its subrogation and reimbursement rights against Defendant Dawson. In connection with a Texas state court action against a third-party responsible for Dawson’s injuries, Continental and Aetna intervened in the state lawsuit, asserting liens upon any settlement or judgment. Dawson and Continental executed a settlement agreement for a complete discharge of Continental’s liability for compensation and past medical care. Thereafter, Aetna filed a claim with the DOL against Continental for reimbursement of medical benefits Aetna paid on Dawson’s behalf and they agreed to settle the claim. The court found that the terms of an agreement between Aetna and Continental, where Aetna assigned to Continental its subrogation and reimbursement rights connected to Dawson’s medical treatment, did not preclude Continental from enforcing the subrogation rights that Aetna had assigned to it nor did it limit Continental’s recovery from Dawson to the amount of its lien specified in the Agreement, which Dawson had already paid. Under the settlement, Aetna agreed both to assign the full value of its $282,774.51lien against Dawson and to assist Continental in collecting that lien in Dawson’s then-pending state lawsuit. The Fifth Circuit reversed and remanded the district court’s grant of summary judgment in favor of Dawson.
Fund has subrogation interest in wrongful death lawsuit. Mackey v. Johnson, No. 14-CV-2024 (PAM/LIB), 2016 WL 953230 (D. Minn. Mar. 14, 2016) (Judge Paul A. Magnuson). This case presents the question of whether an ERISA plan has the right to recover money paid to a plan beneficiary’s heirs under Minnesota’s wrongful death statute. The court held that Minnesota’s wrongful death statute is not limited only to those claims that are pure wrongful death claims. Thus, the Trustees have a subrogation interest in the medical malpractice action against Defendant.
Forum-selection clause in employment agreement is enforceable. Enkema v. FTI Consulting, Inc., No. 3:15-1167, 2016 WL 951012 (M.D. Tenn. Mar. 14, 2016) (Judge E. Clifton Knowles). Defendant moved to compel mediation and arbitration and to dismiss the complaint which Plaintiff brought for breach of contract, tortious interference with prospective business relationships, fraud, and violation of ERISA. The relevant Employment Agreement requires that the parties mediate, and then arbitrate their disputes. Section 24(g) of the Employment Agreement provides in full:
(g) NOTWITHSTANDING ANYTHING TO THE CONTRARY IN THIS AGREEMENT, IN THE EVENT THE CONTROVERSY, CLAIM, DISPUTE OR DISAGREEMENT ARISES UNDER ANY PROVISION OF SECTION 11, 12 OR 13 OF THIS AGREEMENT, EITHER PARTY SHALL NOT BE REQUIRED TO SUBMIT SUCH MATTER TO ARBITRATION, BUT IN ITS OR THEIR SOLE DISCRETION, MAY BRING LEGAL ACTION IN ANY STATE OR FEDERAL COURT SITUATED IN BALTIMORE, MARYLAND AND EMPLOYEE HEREBY CONSENTS TO THE JURISDICTION OF SUCH COURT AND PERSONAL JURISDICTION THEREIN. THE PARTIES AGREE TO WAIVE JURY TRIAL IN CONNECTION WITH ANY OF SUCH ACTIONS.
The court agreed with Defendant that the only logical reading of the forum-selection clause is that the parties must either arbitrate, or if one of them chooses not to arbitrate, that party may file suit, but only in Baltimore. Since Plaintiff has chosen not to arbitrate, the court found that his only alternative is a legal action in Baltimore. The court ordered that the action be transferred to the United States District Court for the District of Maryland in Baltimore.
* Please note that these are only case summaries of decisions as they are reported and do not constitute legal advice. These summaries are not updated to note any subsequent change in status, including whether a decision is reconsidered or vacated. The cases reported above were handled by other law firms but if you have questions about how the developing law impacts your ERISA benefit claim, the attorneys at Roberts Disability Law may be able to advise you so please contact us. Case summaries authored by Michelle L. Roberts, Partner, Roberts Disability Law, 1050 Marina Village Pkwy., Ste. 105, Alameda, CA 94501; Tel: 510-230-2090.
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