Is there any evidence of a conflict of interest that is discoverable to support a claim that evidence outside the administrative record should be considered upon de novo review?

Two district courts have addressed similar discovery issues, finding that information regarding a conflict of interest is discoverable to support the plaintiff's claim that evidence outside the administrative record should be considered upon de novo review. In Sheehan v. Metropolitan Life Ins. Co., 2002 WL 1424592 (S.D.N.Y.2002), plaintiff requested the production of documents and depositions in order to discover whether the defendant plan administrator had a conflict of interest when it terminated plaintiff's disability benefits. The magistrate judge noted that a conflict of interest may constitute good cause to allow the district judge to consider evidence outside

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