to contract reformation, the Court will too. (See Pis.’ Br. [Doc. # 317] at 36-40; Br. for Sec’y of Labor [Doc. # 329] at 15-19.) Equity courts traditionally had the power to reform contracts that failed to express the agreement of the parties, owing either to mutual mistake or to the fraud of one party and the mistake of the other. See Amara III, 131 S.Ct. at 1881 (“Equity courts ... would reform contracts to reflect the mutual understanding of the contracting parties where fraudulent suppressions, omissions, or insertions materially affected the substance of the contract, even if the complaining party was negligent in not realizing its mistake .... ” (quotation marks, citations, and alterations omitted)); see also Nechis v. Oxford Health Plans, Inc., 421 F.3d 96, 103 (2d Cir.2005) (<HOLDING>). A plaintiff must prove mistake and fraud by
recognizing fraud mutual mistake or terms violative of erisa as bases for reformation recognizing fraud in the inducement as defense under federal common law interpreting erisa holding that a mistake sufficient to justify rearrest must be tinged with fraud or misrepresentation recognizing cause of action for equitable estoppel under erisa recognizing that a release is subject to avoidance on grounds such as fraud or mistake