Segal v. Asics America Corp.

Summary

The court held that costs for trial exhibits and demonstratives prepared but not used at trial are not categorically recoverable under section 1033.5(a)(13), because that provision requires the items to have actually assisted the trier of fact. The same costs may nevertheless be awarded under section 1033.5(c)(4) in the trial court’s discretion if they were reasonably necessary to the litigation and reasonable in amount, so the court affirmed the judgment below on narrower grounds.