Illinois Bar Journal

Author Index Robert D. Kreisman

Creditors Are Not Freeloaders: The Common Fund Doctrine Does Not Apply to Hospital Lienholders

By Robert D. Kreisman
November
2011
Article
, Page 568
Wendling holds that hospital lienholders are creditors, not third-party beneficiaries of the plaintiff's lawsuit, and thus not required to pay attorney fees under the common fund doctrine.
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