1, 1975.” The district court concluded that section 1144, despite its express limitation to preemption questions, also acted as an implicit restraint on ERISA’s jurisdictional authorization. The district court held that if the critical acts occurred before 1975, ERISA would not have preemptive force and federal subject matter jurisdiction would not exist. Turning to the question of when the critical acts occurred, the court concluded that the acts occurred before 1975. Lee contends: (1) that the district court erred in <HOLDING>, and (2) that, in any event, the critical acts occurred after January 1,1975. We disagree with Lee on both points and affirm the trial court’s decision. There is no dispute that L d 838, 840-41 (1st Cir.1981) (<HOLDING>). Menhom is the law of this circuit, however,
holding that duration of limitation is a factor in determining whether limitation is significant holding immunity from liability is not jurisdictional holding time limitation on statement of costs is not jurisdictional and late filing is within courts discretion holding that section 1144 is a jurisdictional limitation holding that exhaustion of issues is jurisdictional