"The de novo standard extends to both plan interpretation and factual findings, and the Court is not confined to the record before the Plan administrator," but may also consider supplemental evidence. Levine v. Life Ins. Co. of N. Am., 182 F. Supp. 3d 250, 258 (E.D. Pa. 2016) (citing Luby v. Teamsters Health, Welfare, & Pension Trust Funds, 944 F. 2d 1176, 1185 (3d Cir. 1991)); Daniel S. Bowerman, D.C. v. Nat'l Life Ins. Co., Civ. No. 13-3345, 2014 WL 7150038 at *8, 2014 U.S. Dist. LEXIS 173952 at *23 (E.D. Pa. Dec. 16, 2014). However, "[i]f the record on review is sufficiently developed, the district court may, in its discretion, merely conduct a de novo review of the record of the administrator's decision, making its own independent benefit determination.
See Bike & Build Ex. M. at NAUT 00219. The fact that the Nautilus representative who drafted the initial ROR letter failed to identify additional reasons why the Auto Exclusion might bar coverage for Anderson's injuries does not mean the Exclusion is ambiguous. SeeDaniel S. Bowerman, D.C. v. Nat'l Life Ins. Co. , No. 13-3345, 2014 WL 7150038, at *9 (E.D. Pa. Dec. 16, 2014) (holding an "initial, early mistake" by the insurer in interpreting its policy "does not prove that the [p]olicy ... [is] ambiguous as a matter of law"), aff'd , 654 F. App'x 550 (3d Cir. 2016) ; cf.Viera , 642 F.3d at 419 ("Disagreement between the parties over the proper interpretation of a contract does not necessarily mean that a contract is ambiguous." (citation omitted) ).