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District Court Rules Administrative Remedies Exhaustion Requirement Does Not Apply to Fiduciary Breach Claims
Health Plan Law 
[Guidance Overview] June 27, 2007
"United States District Court Judge Lawrence M. McKenna [of the Southern District of New York] handed down another ruling in the American Medical Ass'n v. United HealthCare Corp litigation, granting in part and denying in part the defendants' motion for summary judgment on several issues including standing and exhaustion of administrative remedies."
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