N.C.P.I.—Civil 810.44B

(Use for claims arising on or after 1 October 20112

when there is a stipulation as to the reasonableness of

the amount of expenses but not the causal nexus of

the expenses to the conduct at issue. For claims

arising before 1 October 2011, use N.C.P.I.-Civil

810.44.)

Medical expenses include all [hospital] [doctor] [drug] [state other

expenses] bills reasonably incurred3 by (name deceased) as a [proximate

result of the negligence] [result of the wrongful conduct] of the

defendant.

To be reasonably incurred, medical expenses must have been: (1)

reasonably necessary for the proper treatment of (name deceased),4 (2)

incurred as a [proximate result of the defendant's negligence] [result of

the defendant's wrongful conduct] and (3) reasonable in amount.

It is [admitted] [stipulated] that the amount of the medical

expenses paid (and the amount necessary to satisfy medical expenses

that have not yet been paid) is $_______. I charge you that when the

amount actually paid for medical expenses (and the amount necessary to

satisfy medical expenses that have not been paid) [is] [are] shown or

agreed, the law presumes that [this amount is] [these amounts are]

reasonable. Therefore, you will accept as conclusive and binding on you

that the amount of $______ is reasonable.

Additionally, the plaintiff must prove by the greater weight of the

evidence that the medical expenses shown on the bills were reasonably

necessary for the treatment of (name deceased) and that the expenses

were incurred by (name deceased) as a [proximate result of the

defendant's negligence] [result of the defendant's wrongful conduct]. [I

already have instructed you on the definition of proximate cause, and

that definition applies equally here.]5