Local 841 Health & Welfare Fund v. Hickman, et al.
190 Ill.App.3d 658, 546 N.E.2d 1056, 138 Ill. Dec. 1 (5th dist. 1989)
Words & Phrases
Subrogation: In General
Trial Judge
Welch
Holding
Health insurer may not proceed with subrogation action until the insured recovers from third party.
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