Hargreaves, Francis

Lien claimant David Bresler, M.D., who treated applicant Francis Hargreaves for a 2009 industrial injury, sought reconsideration of a WCJ's January 14, 2025 Findings and Order. The WCJ had found defendant liable for payment of the lien ($6,848.68) plus the statutory increase under section 4603.2(b)(2), interest, and a 10% penalty under section 5814, but declined to impose sanctions or refer defense counsel to the State Bar. The lien claimant argued for four section 5814 penalties at 25% each, claimed defendant fabricated its bill reviews, and sought a State Bar referral of defense counsel. The Board granted reconsideration, holding that section 5814 penalties belong to the applicant and are not awarded to lien claimants—instead, a lien claimant's penalty remedy lies under section 4622. The Board rescinded the F&O and returned the matter to the WCJ for further proceedings consistent with its opinion.