While CCP 1033.5(b)(3) generally disallows an award of costs for the expense of photocopying, section 1033.5(a)(13) allows an award of costs for preparation of exhibits “if reasonably helpful to aid the trier of fact.” This decision holds that “trier of fact” refers to any resolution by judge or jury of facts, whether on motion or at trial. So the cost of photocopying exhibits needed to illustrate prior litigation and therefore helpful to the judge, acting as a trier of fact, on a vexatious litigant motion, is a cost that may properly be awarded to the prevailing party.