Bell v. Hawaiian Airlines, Inc., 2000 U.S. App. LEXIS 3674 (9^th Cir. Mar. 8, 2000) (unpublished)-This court found that the district court erred in granting summary judgment for Hawaiian Airlines.  Bell claimed that it violated ERISA's disclosure requirements.  Apparently, the Retirement Board of the Hawaiian Airlines plan treated Mr. Bell's letters to the plan as simple demands for benefits.  This court pointed out that "although it is true that '[a] demand for benefits is not a written request' for information, Moothart v. Bell, 21 F.3d 1499, 1503 (10^th Cir. 1994), courts could reasonably interpret these two letters, viewed in context, as both requests for information and demands for benefits.  Thus, summary judgment was improper.