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Court Grants Limited Discovery – D. MD.

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  • Court Grants Limited Discovery – D. MD.

    Here’s a very brief letter order out of the District of Maryland on the case of Chughtai v. Metropolitan Life Insurance Company. The court rules that limited discovery is allowed.

    This letter order memorializes the August 30, 2019 conference call regarding Plaintiff’s request for extra-record discovery, ECF No. 21, which the parties briefed by letter prior to the call, ECF Nos. 24, 28. I granted the request as follows: Discovery will be limited to interrogatories and will encompass the following: (1) hourly compensation and total compensation for Dr. Goldman and Dr. Schroeder between 2011 and 2016; (2) total number of disability claims Metropolitan Life Insurance Company (“MetLife”) processed under that plan during that same period; (3) breakdown of each of the two doctors’ recommendations during that period (how many recommended denials and how many recommended payments); and (4) breakdown of MetLife’s decisions in response to those recommendations (how many times did MetLife deny after a recommended denial, and how many times did it pay after a recommended payment). MetLife will have thirty days to respond to the interrogatories. The parties will jointly propose a revised briefing schedule in light of this ruling. What follows is a more detailed analysis of the issue.
    The court reasons that discovery is allowable because:

    Plaintiff alleges that the 758-page administrative record contains only about 34 pages of “actual MetLife analysis.” Pl.’s Reply 1, ECF No. 28. She then argues that the physicians’ reviews were “poorly reasoned” and failed to take account of various indications that Plaintiff was unable to work. Id. at 1, 3. She contends: “The only reason that satisfactorily explains MetLife’s behavior is it allowed conflict of interest to impact its benefits decision.” Id. at 3. In support of this assertion, she alleges that the physicians who worked on Plaintiff’s case did not conduct examinations, but merely reviewed files. She also singles out two of those physicians, Drs. Goldman and Schroeder, as potentially suspect. With regard to Dr. Goldman, she alleges that federal courts have repeatedly reversed denials that had been based at least in part on his opinions, and that the Sixth Circuit once characterized one of his opinions as “factually and analytically problematic.” Id. As for Dr. Schroeder, she alleges that he stated in a 2006 deposition that he worked exclusively for insurance companies in disability cases, spent just one hour on the case at hand, and that he did not know whether the records he reviewed were complete. Id.

    Plaintiff has met her burden of establishing that the administrative record does not provide sufficient evidence to address her assertion that MetLife’s decision was affected by bias. See Kane v. UPS Pension Plan Bd. of Trustees, No. RDB-11-03719, 2012 WL 5869307, at *4 (D. Md. Nov. 19, 2012). On that basis, I approve Plaintiff’s request for extra-record discovery.
    The very brief letter order is attached hereto.
    Attached Files