MEMORANDUM
J. FREDERICK MOTZ, District Judge.
On November 5, 2007, plaintiff Keith Bowling ("Bowling") filed suit under the Employee Retirement Income Security Act of 1974 ("ERISA"), 29 U.S.C. §§ 1001 et seq., challenging the termination of his long-term disability benefits by defendants PBG Long-Term Disability Plan and VPA, Inc. ("VPA"). VPA filed a counterclaim requesting an equitable lien on alleged overpayments made to Bowling. Now...
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