(December 12, 2017, 12:20 PM EST) -- NEW YORK — A federal judge on Dec. 8 entered judgment for a health insurer in an Employee Retirement Income Security Act case, finding that denials issued during the precertification process did not render any further attempts at administrative remedies futile where the plan specifically required an appeal from the explanation of benefits (Sandra A. Peppiatt v. Aetna Life Insurance Co., et al., No. 17-2444, E.D. N.Y., 2017 U.S. Dist. LEXIS 199895)....