Santos, Britzi

Britzi Santos, a 66-year-old painter for the Los Angeles County Sheriff's Department, sustained an admitted COVID-19 injury on January 4, 2021. The parties entered into a joint stipulation that became a final Order and Award (June 8/9, 2023), but defendant failed to pay. After applicant filed a DOR to enforce, the WCJ found defendant failed to comply, awarded Labor Code section 5814 penalties, interest, attorney's fees, and costs, and denied defendant's claim for credit for TD payments allegedly made under Los Angeles County Code section 6.20.070. Defendant petitioned for reconsideration, arguing lack of substantial evidence, failure to meet burden of proof, no basis for penalties, and erroneous credit denial. The WCAB denied reconsideration, adopting the WCJ's Report, which held that a stipulation converted to a final order must be enforced and that defendant failed to timely raise or reserve any credit claim.