ARNOLD, Circuit Judge.
LaVerne Johnson and Paul Edwards filed suit against their former employer, Lend Lease Real Estate Investments, Inc., claiming that letters that Lend Lease sent to them upon termination of their employment constituted free-standing ERISA plans under the Employee Retirement Income Security Act of 1974 (ERISA), see 29 U.S.C. §§ 1001-1461, and contesting Lend Lease's decision to terminate the benefits provided in the letters. Lend...
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