Employee Retirement Income Security Act (ERISA) cases have their own set of rules. Two things stand out about ERISA cases. One is that a person is not entitled to a jury trial in an ERISA case, rather a Judge reviews the administrative record in the case when deciding who is going to prevail in the case. Two is that there is very little to no discovery in the case.
This is illustrated in the 1998, 5th Circuit Court of Appeals opinion, Vega v. National Life Ins. Services, Inc.
Vega is a summary judgement case where Vega is appealing the decision rendered against hit. Part of his appeal addresses how the Court ruled as it relates to discovery in the case.