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The court affirmed the trial court's damages award for the emerald ring ($31,500) and brooch ($8,000) based on expert testimony regarding fair market value, but reversed and remanded on the diamond bracelet damages due to insufficient evidence of value.
CONVERSION – DAMAGES – MARKET VALUE - EXPERT TESTIMONY : The trial court did not err in its determination that the testimony of plaintiff's expert witness was sufficient to establish, beyond mere speculation, the value of damages for conversion of plaintiff's ring and brooch. The trial court erred when it determined that plaintiff's failure to present expert testimony on the value of her diamond bracelet precluded a recovery of damages for that item, because lay testimony, or a combination of lay and expert testimony, may be enough to prove damages under certain circumstances.
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