Mealey's (January 4, 2019, 12:13 PM EST) -- BAY CITY, Mich. — A disability claimant cannot supplement the administrative record to include a letter from the disability insurer awarding her benefits because the letter was issued after the district court determined that the claimant is not entitled to an award for attorney fees and costs, a Michigan federal judge said Dec. 10 in denying the claimant’s motion (Kimberly J. Guest-Marcotte v. Life Insurance Company of North America, et al., No. 15-10738, E.D. Mich., 2018 U.S. Dist. LEXIS 208252)....