Costs: With Respect Trial Transcription Costs, Court Reporter Fee Are Awardable But Transcript Preparation Is Not Unless Transcripts Ordered By The Court

Also, Messenger And E-Filing Charges Are Allowable In The Court’s Discretion.

               McCluskey v. Hendricks, Case No. B331457 (2d Dist., Div. 2 July 16, 2024) (unpublished) reinforced these principles for recovery of routine costs: (1) court reporter fees for trial transcription are recoverable (CCP § 1033.5(a)(11); Gov. Code, § 68086(d)(2)); (2) actual trial transcript preparation costs are not recoverable unless ordered by the court (CCP § 1033.5(b)(5)); and (3) messenger and e-filing charges are allowable in the discretion of the lower court if reasonably necessary for the litigation.