Safavi

FACTS

Safavi received a series of dental treatments from Dr. Kristen Ritzau and her dental practice, Kristen Ritzau, D.D.S., Inc. (collectively, Ritzau). After experiencing severe mouth pain, Safavi filed a complaint against Ritzau and another dental provider, Dr. Colby Livingston, for professional negligence and lack of informed consent. Livingston and Ritzau, represented by separate counsel, conducted discovery, which included deposing Safavi and subpoenaing records from her other providers. Livingston and Ritzau each filed a motion for summary judgment. The trial court granted both motions and entered judgments in their favor. Livingston and Ritzau then each filed a costs memorandum, with Livingston seeking $9,679.20 and Ritzau seeking $7,581.18. Among other costs, Ritzau sought $2,789.25 for Safavi’s deposition and over $3,000 in subpoena fees and CourtCall fees. Safavi appealed the judgment in favor of Ritzau. A different panel of this court affirmed, finding Safavi’s claims against Ritzau were barred by the statute of limitations. (Safavi v. Ritzau (Dec. 21, 2022, G060189 [nonpub. opn.].)

2 Safavi filed a motion to tax costs, asserting several of Ritzau’s claimed costs…