1. Whether a covered entity violates ERISA, by improperly denying
beneficiaries' rights and further compounds such violations by
approving unauthorized benefits while withholding medical records in
its entirety, in order to avoid liability and to conceal its breaches of
fiduciary duties?

2. Where a Plan's fiduciary holds the authority and sole responsibility of
adjudicating claims governed by ERISA and fails to follow the terms
under the Plan, would a beneficiary have the equal right to challenge a
fraudulent claim/determination under the same standard of review as
a denied claim for relief pursuant to ERISA §§ 502(a), 502(a)(3)?

Whether a covered entity violates ERISA, by improperly denying beneficiaries' rights and further compounds such violations by approving unauthorized benefits while withholding medical records in its entirety, in order to avoid liability and to conceal its breaches of fiduciary duties?