Whether or not the District court borrowed the appropriate state law for Erisa statutory penalty by applying a one year statue of limitations under O.C.G.A. § 9-3-28, even though the Georgia Supreme Court suggests that the limitation is twenty years under O.C.G.A. § 9-3-22 for aggrieved Georgians.

Whether or not an assignee of benefits only has the authority to request ERISA plan documents from the plan administrator even if the original assignment does not confer rights to pursue statutory penalties claims.

Whether or not a designated authorized representative has the authority to request ERISA plan documents from the plan administrator.

Whether or not a retroeffective assignment that expressly confers rights to statutory penalties claims is valid if the original request came from a party that had the authority to request plan documents in accordance with ERISA claim and appeal procedures.

Whether the District court borrowed the appropriate state law for ERISA statutory penalty