Which Party Pays the Costs of Document Disclosure, Including Multi-Language Translation?
Rosado’s shortcoming is that it says nothing about who should pay the costs of production. As to this question, one turns to the case of Schroeder v. Centro Pariso Tropical which, briefly, states that the defendant in the litigation was not required “to help a third party defendant defray the costs of its own discovery”. From here, one must also look at Rubin v. Alamo Rent-a-Car, which, on appeal, stated that “each party should shoulder the initial burden of financing his or her own suit” and based upon such a principle, it is the party seeking discovery of documents who should pay the cost of their reproduction.
