Segal

Opinion of the Court by Cantil-Sakauye, C. J.

A prevailing party in civil litigation is entitled to recover costs incurred in the litigation. (Code Civ. Proc., § 1032, subd. (b).) Code of Civil Procedure section 1033.5 1 sets forth specific items of costs that are allowed or prohibited. (§ 1033.5, subds. (a), (b).) The statute also authorizes the trial court in its discretion to award or deny an item of costs not mentioned in this section. (§ 1033.5, subd. (c)(4).) We granted review to resolve a conflict among the Courts of Appeal regarding whether costs incurred in preparing photocopies of exhibits and demonstrative aids for trial are recoverable under section 1033.5 even if they were not ultimately used at trial. In this case, the Court of Appeal held that such exhibit-related costs are recoverable under section 1033.5, subdivision (a)(13) (hereinafter section 1033.5(a)(13)), which allows the recuperation of costs for models, enlargements, and photocopies of exhibits “if they were reasonably helpful to aid the trier of fact.” The court further held that such costs may be awarded in the trial court’s discretion under section 1033.5, subdivision (c)(4) (hereinafter section…