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1049 Randal M. Whitlatch (rwhitlatch@spilmanlaw.com) is an associate in the Charleston, West Virginia, office of Spilman Thomas & Battle, PLLC. SUBROGATION UNDER ERISA AND THE SEARCH FOR “APPROPRIATE EQUITABLE RELIEF” Randal M. Whitlatch i. introduction Given today’s rising health-care costs, employers have been searching for ways to avoid excessive health-care expenses. Employers have attempted to stem the rising costs while still offering benefits by increasing deductiblles raising co-pays, and...

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