In the recent decision of Bokova v. Gertsoyg & Company, 2016 BCSC 2297, the court found that the $21,984.48 cost for an expert report of a Physiatrist was a “reasonably necessary and proper” disbursement. The court said:
 On this review, the client challenges both the fees charged and the disbursements claimed. The client is particularly distressed by the costs of a physiatrist’s report by Dr. Michael Vondette, which totalled $21,984.48, and with the contents of that report. The contingency agreement itself is not challenged.
 The client had the option of having the cost of Dr. Vondette’s report assessed before a registrar pursuant to Supreme Court Civil Rule 14-1(5), but chose to accept the defendant’s partial offer towards the disbursements incurred. That was her choice. However, it does not bind the lawyer. Within this proceeding, the appropriateness of the cost of Dr. Vondette’s report must be reviewed pursuant to the provisions of the LPA. I find the lawyer’s disbursements, including the report of Dr. Vondette, to have been authorized, reasonably necessary and proper to the conduct of the proceeding to which they relate in accordance with s. 71(2) (a) and (b) of the LPA. Accordingly, the lawyer’s disbursements, including the report of Dr. Vondette, are allowed in full.
The full text of the decision can be found here: http://www.canlii.org/en/bc/bcsc/doc/2016/2016bcsc2297/2016bcsc2297.html?resultIndex=1