El Dorado Meat Co. v. Yosemite Meat and Locker Service, Inc.
California Court of Appeal
58 Cal. Rptr. 3d 590 (2007)
El Dorado Meat (plaintiff) sued Yosemite Meat (defendant) alleging fraud and anticompetitive conduct that drove El Dorado out of business; at trial, Yosemite presented a 37-page exhibit summarizing its voluminous business records, and the trial court entered judgment for Yosemite on all claims. Yosemite sought $191,566 in costs, including $143,809 tied to preparing that summary exhibit - $111,063 for personnel (including an accounting firm and data-entry staff) to compile the underlying data, $30,495 to photocopy 160,000 pages of the underlying business records (also admitted into evidence), and $2,250 for courtroom projection equipment. El Dorado objected to the exhibit-related costs, and the trial court nonetheless awarded Yosemite the full amount; El Dorado appealed.
Whether a prevailing party may generally recover reasonable costs for items reasonably necessary to conduct the litigation.