Some Not Properly Awardable/Some Not Reasonably Necessary.
Prevailing party in Betchart v. Ludwig Betchart, Case No. A131137 (1st Dist., Div. 2 Mar. 21, 2013) (unpublished) must have been sorely disappointed when a motion to tax costs reduced a routine costs request from $20,816.87 to $5,370.65. Well, that party was no more happier on appeal. Costs for one party were properly taxed because attorney did not represent the party at the time so that the costs memo verification could not be true. Fees of experts not ordered by the court are not statutorily authorized, ditto for court proceedings transcripts not ordered by the court. Attorney's deposition travel was correctly rebuffed because it was done before his client was a party to the lawsuit. As far as the costs of mediation, there was no prohibition in awarding them as routine costs, but the mediation was voluntary/unsuccessful so as to allow the lower court to conclude it was not reasonably necessary to the litigation.