New York Supreme Court February 15, 1829 (Erwin v. Martin)

On a motion for retaxation of a bill of costs in this case, the court decided that where there are more than four witnesss subpoenaed, a party may charge for the engrossing and seal of as many more subpoenas as are used, allowing one subpoena to every four witnesses. They also decided that no fee is taxable for the service of a paper, unless it is a paper requiring an answer.