(Unjust Enrichment)  11. Upon information and belief, while engaging in these practices, LifePoint routinely seeks payment for the medical bills from those same patients, either directly or indirectly.  12. Upon information and belief, LifePoint seeks payment for medical bills through means that include demanding cash payment directly from the patients, and placing unlawful hospital liens upon patients' third-party tort claims and recovery and/or patients' automobile- insurance benefits (medical-payments benefits and uninsured/underinsured-motorist benefits).  13. LifePoint pursues this course of conduct despite the patients having health insurance and being contractually entitled to have their medical bills submitted to their health insurance carriers for payment.  15. Upon information and belief, LifePoint is precluded by its contracts with health insurance carriers (such as Plaintiff's insurer, United Healthcare) from seeking payment for covered services from other sources, including from the patient directly, or by filing hospital liens.  16. Such patients are unable to submit their medical bills directly to their health insurance carriers because LifePoint is the entity responsible for such submission. LifePoint is the only entity in possession of the information required to make such a submission, and LifePoint is the entity that has a contract with the health insurance carrier for a reduced compensation for treating patients with health insurance.  17. Through LifePoint's billing and bill-collection practices, it attempts to maximize the amount it receives for covered services by seeking from patients the full amount charged (which is more than it is entitled to receive for the covered treatment), rather than accepting the discounted amount it has contractually agreed to accept as full payment, except for copays and deductibles, from the patients' health insurance carriers. Upon information and belief, LifePoint derives considerable profit from this policy and business model.  19. On May 19, 2015, Plaintiff was involved in an automobile accident in Covington County, Alabama. On the day of the accident, she was transported by ambulance to Andalusia Regional Hospital for emergency-room ("ER") treatment for injuries she received in the wreck.  20. At that time, Plaintiff had health insurance with United Healthcare, which covered the ER services she received. Andalusia Regional Hospital did not submit Plaintiffs medical bills to United Healthcare for payment. Instead, Andalusia Regional Hospital charged Plaintiff the undiscounted sum of $11,740.75 for ER services rendered. Pursuant to Plaintiffs health insurance policy with United Healthcare, however, Plaintiff only owed Andalusia Regional Hospital a $150 copay.  21. Andalusia Regional Hospital subsequently obtained $5,000 in med pay from Plaintiffs automobile insurer, Allstate. Andalusia Regional Hospital applied this sum to the payment of Plaintiff's undiscounted medical bills.  22. On June 10, 2015, Andalusia Regional Hospital filed a hospital lien for $6,740.75 in Covington County, Alabama, on all claims or demands accruing to Plaintiff on the account of her injuries. The lien recited that it was filed by "Andalusia Regional Hospital - LifePoint" "operated by/owned by LifePoint."  24.	 On May 4, 2016, Plaintiff's personal-injury attorney used $6,740.75 from the settlement to pay Andalusia Regional Hospital and satisfy the hospital lien, as the lien was preventing Plaintiff from receiving any compensation for her injuries. 25. This action is brought as a plaintiffs' class action pursuant to Federal Rule of Civil Procedure 23(b)(3). Plaintiff brings this action on her own behalf, and on behalf of all others similarly situated, as representative of the following Class: All persons in the United States who received any type of healthcare treatment from any healthcare facility that is owned or operated by LifePoint Health, while covered by private health insurance or while a participant in a group health and welfare plan (hereinafter collectively referred to as "health insurance"), and within six years preceding the commencement of this action, whose medical bills for covered treatment were not submitted to the patient's health insurance carrier for payment, and LifePoint Health Obtained payment for the undiscounted medical bills directly from the patient, and/or from the patient's third-party tort recovery and/or automobile-insurance benefits (medical-payments benefits and uninsured/underinsured-motorist benefits), or LifePoint Health placed a hospital lien on the patient's third-party tort claim and/or automobile-insurance benefits which has not been satisfied. Excluded from the Class are (1) the officers, directors, and employees of LifePoint Health, and of healthcare facilities owned or operated by LifePoint Health; and (2) all judicial officers of the United States who preside over or hear this case, and all persons related to them as specified in 28 U.S.C. § 455(b)(5).  26. The members of the Class are readily identifiable from the information and records in the possession or control of LifePoint.  29. Plaintiff's claims are typical of those of the Class and are based on the same legal theory as those of the Class members. Plaintiff's claims and those of the Class members all arise from the same pattern or practice by LifePoint, set out above.  30. Plaintiff will fairly and adequately protect the interests of the members of the Class. Plaintiff has retained counsel who are highly experienced and competent in complex consumer class-action litigation, and Plaintiff and her counsel intend to prosecute this action vigorously. Neither Plaintiff nor her counsel have any interests that might cause them not to vigorously pursue this action. Plaintiff's interests are coextensive with those of the Class, and Plaintiff has no interests adverse to those of the Class members.  32.	 Plaintiff and her counsel are aware of no litigation concerning the controversy already begun by or against Class members. This also indicates that the Class members' interest in individually controlling the prosecution of separate actions is minimal.  33. No difficulties are likely to be encountered in managing this action as a class action. 34. Plaintiff realleges and incorporates by reference all preceding allegations, and alleges as follows against LifePoint on behalf of herself and the members of the Class:  35. Plaintiff and the Class members are intended third-party beneficiaries of the contracts between LifePoint and their health insurance carriers. At the time of contracting, LifePoint and the health insurance carriers intended to confer a direct benefit upon Plaintiff and the Class members, in that LifePoint would submit Plaintiff's and the Class members' medical bills to their health insurance carriers for payment at discounted rates, whereby Plaintiff and the Class members would only be obligated to pay copays and deductibles, and LifePoint Would be precluded from seeking payment for the medical bills, other than for copays and deductibles, from any other source, directly or indirectly, including Plaintiff and the Class members.  37. As a proximate result of LifePoint's breach of its contracts with the health insurance carriers, Plaintiff and the Class members were damaged. They paid for undiscounted medical bills they were not indebted to pay, they lost insurance proceeds they were entitled to receive, and/or they lost money they were entitled to receive from third-party tort recoveries. In the case of Class members with unsatisfied hospital liens, they cannot access funds subject to the liens that they are entitled to receive and have lost the use of those monies. 38. Plaintiff realleges and incorporates by reference Paragraphs 1 through 37 above, and alleges as follows against LifePoint on behalf of herself and the members of the Class:  39. As alleged above, LifePoint has engaged in a pattern of subverting the financial interest and insurance agreements of Plaintiff and the Class, for its own pecuniary gain.  40. LifePoint has filed hospital liens for the undiscounted medical bills upon Plaintiff's and the Class members' third-party tort claims and recoveries and/or automobile- insurance benefits, and has obtained payment for the undiscounted medical bills from the Class members' third-party tort recoveries and/or automobile-insurance benefits, and/or from the Class members directly.  41. LifePoint has been unjustly enriched because it received and retained the benefit of proceeds to which it was not entitled.  42. LifePoint unjustly retains benefits it received at the expense of Plaintiff and the Class members.  44.	 Therefore, LifePoint holds monies which in equity and good conscience belong to Plaintiff and the Class members. 5. LifePoint is a healthcare company that owns and/or operates hospitals in twenty- two states. LifePoint owns and/or operates two hospitals in the State of Alabama, Andalusia Health, also known as Andalusia Regional Hospital, in Andalusia, Alabama, and Vaughan Regional Medical Center in Selma, Alabama. LifePoint is a for-profit healthcare company.  6. Upon information and belief, LifePoint controls the manner, methods, and means of the billing practices and bill-collection practices at the hospitals it owns and/or operates, such that those hospitals are LifePoint's agents for the purposes of their billing and bill-collection practices.  7. Upon information and belief, the billing and bill-collection practices described herein are conducted by the hospitals owned and/or operated by LifePoint at LifePoint's direction and under its control, such that these activities are the actions of LifePoint as its agents' principal.  8. LifePoint, as described in detail below, routinely subverts the financial interests of its patients for its own benefit and profits through unlawful and predatory billing practices.  9. Upon information and belief, LifePoint screens all patients and makes a determination regarding the reason for treatment and whether there may be sources of payment other than health insurance available.  BREACH OF CONTRACT (ThirdParty Beneficiary) 