Demonstratives can be taxed in E.D. Wash.
The Eastern District of Washington’s guide on the Taxation of Costs states that the provision of 28 U.S.C. 1920 addressing exemplification costs includes demonstratives used as trial exhibits. It allows for the prevailing party to be reimbursed for the cost of such exhibits provided that it gets the Court’s permission to tax this cost.
Specifically, the Guide states that, “[e]xemplification costs may also include those charged by a third-party technology vendor to produce demonstrative evidence used at trial.”