You have not given enough information here for a proper response. Since you are from D.C., perhaps Sam is from D.C. also. In that case, and if Sam's accident was in D.C., she would not have sought PIP in all liklihood if she wanted to pursue a case against the other driver. I hope you are not suggesting that Sam received medical care that she did not need. In any event, Sam could call me if she would like more information.
I'm not a D.C. attorney, but my guess on this would be: it depends on what her settlement was. If the car insurance policy paid the entire policy limit, then it wouldn't matter if her damages (including medical bills) wildly exceed the settlement as the policy limit was likely all she would ever extract out of the defendant anyway. But if the medical bills were, say, $25,000 but the case settled for just $2,000, now you might have a scenario where the attorney should have "submitted" the bills. I'm not sure what "submitted" means here in the way you use it.
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