laches, but it is tough to prevail on this defense. You need to try to do discovery on pltf for things that would help you defend on the merits. if pltf doesnt have the documents anymore or theyve been lost etc, that could help your laches defense. Try to subpna records re payment or medical coupon etc. if those are no longer available, that helps the defense. probably should try to get some help from a local atty.
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