Plaintiff relying on medical records to prove her injury and not submitting medical bills.
Plaintiff’s medical bills not relevant evidence and should be excluded from argument and introduction as evidence.
In the alternative, argument that medical expenses incurred by plaintiff are relevant to pain and suffering should be excluded.
Defendant should be precluded from making statement, suggestions, or argument that jury should base their damage award for Plaintiff’s pain and suffering on dollar amount of medical care or amount of medical care Plaintiff had following incident.