Where defendants' conduct has caused a plaintiff to relocate interstate, those defendants cannot resist recovery of the plaintiff's travel and accommodation costs incurred in prosecuting the action in the original jurisdiction. Voluntary clerical assistance from friends and relatives is not recoverable as costs, but actual out-of-pocket clerical expenses are. A successful plaintiff who fails on some causes of action sharing a common factual matrix should generally not have costs reduced, though a modest reduction may be appropriate where a late-added claim introduced additional facts that prolonged the trial.
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