In Berkeley Cement, Inc. v. Regents of the Univ. of California (2019) 30 Cal.App.5th 1153, the court confirmed that a trial court may award mediation fees as costs, whether the mediation is court ordered or privately agreed to. In affirming the award of mediation fees as costs, Berkeley Cement noted that although mediation costs are not expressly allowable in the Code of Civil Procedure, such costs “fall within the category of costs that may be awarded in the trial court’s discretion.” (Id. at p. 1140.)