Silva, Martha

Martha Silva, a substitute teacher, filed a workers' compensation claim for back and knee injuries that was initially denied by the defendant. Supreme Copy Service, as lien claimant, issued 10 subpoenas to obtain records for the contested claim and billed the defendant, but the defendant did not pay or timely object for nearly two and a half years. The WCJ found a contested claim existed, that the copy service expenses were reasonably incurred as medical-legal costs, calculated reasonable values based on what defendant historically paid, and assessed penalties and interest under Labor Code section 4622. Defendant petitioned for reconsideration challenging the burden of proof, the absence of records/declarations, mileage charges, and the imposition of penalties and interest. The WCAB adopted and incorporated the WCJ's report and denied reconsideration.