Maria Aguilera De Gonzalez — ADJ8904686, ADJ8196287

Barrington Psychiatric and Tina Dyck sought reconsideration of a November 24, 2020 Joint Order requiring them to pay Travelers Insurance $10,652.00 in attorney's fees and costs under Labor Code section 5813 for defending against an allegedly invalid and baseless lien. The Board found that the prior June 21, 2019 Findings and Order establishing liability for sanctions was final because lien claimant did not seek a writ of review of the September 30, 2019 denial of reconsideration, leaving only the reasonable value of defendant's costs at issue. The Board determined the record was insufficient under Hamilton v. Lockheed Corp. because the October 12, 2020 minutes of hearing lacked detail on the parties' arguments, did not reference lien claimant's objections, and the invoices supporting the $10,652.00 were never admitted into evidence. The WCJ also failed to issue a Report and did not explain how the fee amount was determined to be reasonable. The Board rescinded the Joint Order and remanded for further proceedings to create a proper record.