The following excerpt is from Waggener v. Unum Life Ins. Co. of America, 238 F.Supp.2d 1179 (S.D. Cal. 2002):
Nonetheless, an administrator's conflict of interest is also relevant to the question of what, if any, evidence the district court will consider outside of the administrative record. Where the district court is reviewing a plan administrator's decision for abuse of discretion, such review is strictly limited to the evidence in the record. Taft v. Equitable Life Assurance Society, 9 F.3d 1469, 1472 (9th Cir. 1993). In addition, in most cases where the district court is reviewing the plan administrator's decision de novo, "additional
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