17 year old Karen Smith was in an automobile accident on February 1, 2018. She was taken to the emergency room of General Hospital in Prince Georges County, MD. Karen sustained various injuries to her head and was unconscious when she arrived at the hospital. Unable to find any identification and due to the severity of her injuries, the attending physician, Steve the cutter Jones treated Karen immediately even though there was no agreement regarding payment. In his overzealous manner, Steve also took out Karens appendix while performing exploratory surgery, even though it appeared healthy, and accidently removed three toes on Karens left foot. Several hours after she was admitted, Karen regained consciousness; she remained in the hospital for three days. Karen fully recovered from her injuries.

In March, 2018, the hospital billed Karen $75,000 for her hospital stay, charging $35,000 for the head injuries, $30,000 for the exploratory surgery and appendectomy, and $10,000 for the toe amputation. In April, 2018 these bills remain unpaid. The hospital file shows that previous attempts to collect this debt from Karens parents have failed, and that Karens parents moved out of State several months ago. Karen resides in the state of Maryland, holding a job as an office receptionist. Due to the expense, Karen does not currently and did not have health insurance at the time of the accident.

You work for the law firm of Sharpe, Knife & Slip who received this case last week, and is representing the Hospital. Draft a memo to the senior partner, Mr. Koenig, analyzing how the hospital may move forward and recover this debt from Karen, what defenses Karen may raise, and what, if any, other issues the Hospital may have to be aware of while attempting to collect this debt