Itemization of Medical Expenses in a Personal Injury Lawsuit

A plaintiff must prove that all expenses, including medical expenses, are reasonable and necessary in order to recover for them. Without proof of reasonableness and necessity, the plaintiff fails to prove causation between the tort and the medical bill. A plaintiff who provides the defendant with an itemized list of medical expenses at least 90 days before trial gets a rebuttable presumption that the expenses are reasonable. Tenn. Code Ann. sec. 24-5-113(b). In addition to the presumption of reasonableness, a legible itemization of medical expenses is a much cleaner exhibit for trial than a stack of xeroxed carbon copy medical bills. The itemization can be admitted by the court as a summary under Tennessee Rule of Evidence 1006.
Here is a sample itemization. Download file

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