Richard Cortez — ADJ555322, ADJ1127657, ADJ3643619, ADJ3733400, ADJ615070

Richard Cortez, a union laborer who suffered five specific injuries between 1990 and 1997, sought a retroactive increase in his temporary disability (TD) rate. The WCJ issued a Joint Findings of Fact and Award on 10/31/2022 finding Cortez entitled to a retroactive TD increase under Labor Code section 4661.5, calculating his earnings under section 4453(c)(4) and (d). Defendant (Paramount Pictures, permissibly self-insured, administered by Murphy and Beane) petitioned for reconsideration, arguing the wrong calculation method was used, that no payment delay occurred under section 4661.5, and that laches barred the claim. The WCAB adopted the WCJ's report and denied reconsideration, finding the record supported the use of section 4453(c)(4)/(d), that section 4661.5 applies to any TD payment made two or more years after injury, and that defendant failed to prove laches.