Recovering the past medical expenses requires proof that the charges are reasonable, related to the accident, and necessary. See Garrett v. Morris Kirschman & Co., Inc., 336 So.2d 566 (Fla. 1976).
Interestingly, while expert medical testimony is required to prove the relationship between the accident and the injuries, expert testimony is not always required to prove that the charges are reasonable and necessary. See, Id., and Albertson’s, Inc. v. Brady, 475 So.2d 986 (Fla. 2d DCA 1985), rev. denied, 486 So.2d 595 (Fla. 1986).
In Easton v. Bradford, 390 So.2d 1202 (Fla. 2d DCA 1980), the plaintiff’s detailed description of the treatment procedures clearly relating the therapy to the accident, was sufficient to properly admit the bills into evidence.
In contrast, in Albertson’s Inc. v. Brady, 475 So.2d 986 (Fla. 2nd DCA 1985), unlike in Garrett and Easton, plaintiff’s testimony did not associate each medical bill with injuries resulting from the accident. Cf. Polaco v. Smith, 376 So.2d 409 (Fla. 1st DCA 1979).
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