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Insurance – Life – Labor & Employment – ERISA – Policy Conversion Deadline – Equitable Tolling

Even though plaintiff’s decedent, an ERISA plan participant, was incapacitated by illness during the period when he could have converted his employer-provided life insurance policy to an individual policy, and even though the participant tried to make the conversion 26 days after the conversion period ended, the defendant-plan administrator did not abuse its discretion in .

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