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Wednesday, July 05, 2006

Exhausted. The Second Circuit has held that where an employee benefit plan sets up administrative remedies after a claim has already been filed in court, the claimant is deemed to have exhausted his (or her) administraive remedies, pursuant to 29 CFR 2560.503-1(l). The decision in Eastman Kodak Co. v. Coyne can be found here.

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