Article

Recoverable Costs

In a recent opinion, Judge Alesia of the Northern District of Illinois issues an opinion that provides guidance as to what costs a prevailing party can recover. Although the Court refused to allow the defendants to recover costs for ASCII diskettes of depositions, costs for expediting transcripts, and costs incurred in excess of the daily page limit for deposition transcripts, the Court did allow the prevailing defendants to recover cost of laser color prints and reproduction of photographs. The Court noted that the photographs and reproductions were necessary to preserve evidence of condition of property at the time it was returned. Ochana v. Flores, 206 F.Supp.2d 941 (N.D.Ill. 2002).