How the Eastern District of Washington Allows Deposition Costs To Be Taxed

The United States District Court for the Eastern District of Washington has posted a guide online, Bill of Costs Guide - Taxation of Costs by the Clerk, which includes a section on how deposition costs can be taxed under 28 U.S.C. § 1920. Make special note that the Court does not allow a party to be reimbursed for both a PDF of a deposition transcript, and a hard copy of the same transcript without an explanation for why both were needed. The cost of one copy of a transcript, and copies of the exhibits can be taxed. Reimbursement will only be approved for depositions which are used at trial. A party can also seek reimbursement for a reporter's travel expenses and attendance fee.


The following deposition services cannot be taxed:

  • Fees for expediting a transcript.

  • Attorneys' fees and expenses for a deposition.

  • Postal delivery fees for transcript delivery.

  • Phone bills for remote depositions.

  • "Transcript[s] used primarily for trial preparation or discovery."