As I blogged about here, in Hogan-Cross v. MetLife, 2008 U.S. Dist. LEXIS 58027, a federal district court determined that, in light of MetLife v. Glenn, 128 S.Ct. 2343 (2008), the discovery allowed in ERISA cases, at least as to conflict of interest, is as broad as the discovery allowed in any other case in federal district court.   On the heels of Hogan-Cross comes another district court decision to the same effect.  In Paul v. Hartford Life & Acc. Ins. Co, 2008 U.S. Dist. LEXIS 59986, the court was faced with a disability claimant's request for discovery about Hartford's financial conflict of interest.  He claimed Glenn as support for that idea.  In this short opinion the court surveyed a number of district and circuit cases and agreed that discovery as to conflict of interest was allowed.  

Glenn makes it hard to understand how a court could rule otherwise.