§ 1.6.11 LITIGATION RELATED EXPENSES AND COMPUTERIZED LEGAL RESEARCH
| Jurisdiction | Arizona |
In Ahwatukee Custom Estates Management Ass'n v. Bach, 193 Ariz. 401, 973 P.2d 106 (1999), the Arizona Supreme Court held the prevailing party in a contract action may not recover its non-taxable costs, such as delivery and messenger service charges, copying expenses, telecopier and fax charges, postage and long distance telephone charges, as part of an award of attorneys' fees under A.R.S. § 12-341.01(A). The court explained an award of fees should "reimburse the attorney or surrogate for his or her legal...
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