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In a suit to recover the value of professional services, witnesses of proper knowledge and experience may be called to give their opinions under oath as to the value of such services, says the Supreme Court of Colorado in the case of Bourke vs. Whiting, decided Oct. 2, 1893. But such opinions are not conclusive upon the jury; nor is it absolutely essential that expert evidence should be produced in such cases. The jurors have the right, when the nature and kind of services performed are shown in evidence, together with the time and circumstances of performance, to exercise their own judgment in determining the value of such services; and, if parties submit such an issue to the jury without expert testimony, they will not afterwards be heard in complaint.
HOW VALUE OF PROFESSIONAL SERVICES MAY BE PROVED. JAMA. 1893;XXI(20):745. doi:10.1001/jama.1893.02420720029012
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