Garcia, Paul

Cost petitioner Joyce Altman Interpreters provided interpreting services during the pendency of applicant Paul Garcia's case in chief and sought reconsideration of a WCJ's March 23, 2022 Findings of Fact that awarded collection costs but declined to impose separate monetary sanctions under Labor Code section 5813. The WCJ found that defendants' payment of principal, penalties, and interest, though late under AD Rule 9795.4(a), 'counterbalanced' any sanctions, and emphasized the discretionary nature of sanctions. The Board granted reconsideration on its own motion to correct a prior June 5, 2023 decision that erroneously directed sanctions to a party rather than the General Fund. The Board held that because the WCJ had found defendants engaged in bad faith actions or tactics in a medical-legal expense dispute, WCAB Rule 10786(i)(1) mandates monetary sanctions of not less than $500.00. The Board affirmed the Findings of Fact but amended them to impose $500 sanctions against The Hartford and Travelers, jointly and severally, payable to the General Fund.