In Berra v. Danter, the Missouri Court of Appeals, Eastern District, addressed what has been a disputed issue among litigants: whether the reasonable value of plaintiff's medical services may be determined by looking to the amount of medical expenses "incurred," or only by looking to the amount of medical expenses actually paid. The Eastern District held a trial court can consider the amount "incurred" as reflected in plaintiff's medical bill statements, even where the amount actually paid may be substantially lower due to write-offs.
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