The following excerpt is from Burke v. Kodak Retirement Income Plan, 336 F.3d 103 (2nd Cir. 2003):
The facts of Manginaro v. Welfare Fund of Local 771, I.A.T.S.E., 21 F.Supp.2d 284 (S.D.N.Y.1998), provide a useful illustration. In that case, the plan itself imposed a two-year statute of limitations on legal actions against an employee welfare fund. The SPD, however, omitted any mention of the statute of limitations. The normal statute of limitations under New York law would have been six years. Id. at 293.
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