here that the requirements of an amendment of the plan were not satisfied. Therefore, Siegel does not offer support to defendant’s position in this case. 4 . Defendant explicitly declined to argue, both in its brief and at oral argument, that the ACF amended the Policy. In other cases, defendants have argued that non-policy documents were enforceable as amendments, see, e.g., Siegel, 702 F.3d at 1048-49, but in this case, the amendment provision requires any amendment to be "endorsed on, or attached to, the Policy.” (Ex. A to Horbatiuk Aff. at LINA 1242.) Plaintiff did not receive the ACF until discovery, despite earlier requests for his entire claim file, and defendant has not attempted to show that the ACF complied with the amendment rule. See Francis, 2011 WL 4102143, at *4 (<HOLDING>); see also Heim v. Life Ins. Co. of N. Am., No
holding that standing at inception of the suit was not established where the note attached to the complaint was not made payable to the plaintiff and contained no endorsement even though the original note endorsed in blank was introduced at trial holding in the alternative that the acf was unenforceable because it was neither attached to nor endorsed on the policy holding that neither the ada nor the rehabilitation act applies to prison employment holding that neither a letter from the eeoc nor an attached charge of age discrimination qualified as a claim under a claimsmade policy because the documents failed to request money or other relief and only served to put the plaintiff on notice that a demand for relief may subsequently follow holding that the defendants contention was waived because it was supported neither by cogent argument nor citation to authority