Castellano, Julie

Cost petitioner Supreme Copy Service sought reconsideration of a WCJ's Findings and Order that denied its medical-legal cost petition, found Supreme failed to prove a contested claim existed at the time of services, and imposed $1,000 in sanctions plus defendant's costs for proceeding on a frivolous and bad-faith basis. The WCAB found the WCJ erred by concluding that defendant's stipulation to injury to the neck, back, and arm meant no contested claim existed, and by requiring cost petitioner to produce medical evidence. The Board held that the proper analysis under section 4620 turns on whether defendant paid each species of benefit owing, and the record showed multiple disputed, underpaid, or unpaid benefits (including permanent disability and a suspiciously low $15,000 C&R lacking supporting evidence). The Board concluded Supreme met its burden of showing a contested claim and likely met its burden under section 4621, found no evidence supporting laches or sanctions, and rescinded the F&O. The matter was returned to the WCJ to complete the remaining Colamonico analysis.