Commercial Copy Rates Not Helpful When Addressing Reasonable Photocopy Disbursements
A decision was recently publshed by the BC Supreme Court website addressing reasonable photocopy disbursements in an ICBC Claim. Although it is a 2006 decision decided under the old rules, the Court’s comments remain relevant finding that commercial photocopy charges are not helpful when deciding a reasonable rate to charge for photocopy disbursements due to litigant privacy concerns.
In the recently published case (Kind v. Leung) Master Caldwell provided the following observation:
5] There is also information in here about photocopying through commercial endeavours. There are privacy concerns related there and I take counsel’s point, but again the physical cost of copying in those facilities seems to run between five cents and 10 or 11 cents per page.
 Making allowance for in-house copying at a reasonable rate to meet the obligations of privacy and confidentiality, given the costs as I seem to have limited information here in the material relating to equipment, I am not able to indicate or to determine on the material provided by the plaintiff that their costs exceed 30 cents a page. The rate set will be 30 cents per page.
You can click here to access more recent caselaw addressing photocopy disbursements.
bc injury law, disbursements, Kind v. Leung, Master Caldwell, Photocopy charges