Defendant and third-party plaintiff Brenda Hilton is an indigent woman who entered plaintiff Harlem Hospital and received medical services in the fall of 1982. Prior to checking into the hospital, Ms. Hilton applied with third-party defendant Department of Social Services (DSS) for Medicaid benefits. DSS never responded to Ms. Hilton's application and never informed her of her rights regarding further proceedings. Two years later, in 1984, Ms. Hilton was sued by the hospital...
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