S.D. Cal. Local Rule So Allowed.
In Stevens v. CoreLogic, Inc., No. 16-56089 (9th Cir. June 20, 2018) (published), defendant won summary judgment in a case where plaintiff photographers alleged CoreLogic removed copyright management information from photographs and distributed them in such a state in violation of 17 U.S.C. § 1202(b)(1)-(3). CoreLogic filed a Bill of Costs seeking recovery of witness fees for its corporate employees’ attendances at 30(b)(6) and other depositions to support the corporate defendant’s position. The district judge allowed the fees as costs. Photographers appealed, but the Ninth Circuit affirmed. Although generally parties cannot recover witness fees for their own attendance, witness fee expenses to corporate directors/officers are allowable if no recovery is sought against officers individually. Southern District of California Local Rule 54.1(b)(4)(c) does allow for recoverability of such costs “if [the corporate officers] are not parties in their individual capacities.”