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Reindl v. Hartford Life and Accident Ins.

Plaintiff brought this action under 29 U.S.C. 1132(a)(1)(B) claiming that Hartford wrongfully terminated her long-term disability benefits under an employee welfare benefit plan governed by the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001-1461. The court affirmed the judgment of the district court granting summary judgment in favor of Hartford where plaintiff failed to exhaust her administrative remedies by failing to file a timely administrative appeal. The letter at issue could have reasonably been construed by Hartford as a request for documents rather than a request for an appeal.