Espinoza, Alejandro

Interpreter cost petitioner Santana Lopez Interpreting sought $4,849.53 in costs and $13,927.50 in attorney fees for collection efforts to recover a $60.00 balance on a $250.00 invoice for interpreting services at a 05/03/2018 expedited hearing. Defendant had timely paid $190.00 within eight days of services, issued a defective EOR citing a non-existent 'Fast360' contract and an inapplicable fee schedule, and ultimately paid the remaining $60.00 in August 2023 after a cost petition was filed. The cost petitioner argued the defective objection constituted bad faith under Rule 10421 warranting sanctions and fees. The WCJ found, and the Board agreed, that no bad faith was shown because the cost petitioner never established a market rate by documentation at the time of billing, and that the five-year delay in seeking payment further confirmed the absence of bad faith. The Petition for Reconsideration was denied.