Maria Malagon — ADJ10971970

Maria Malagon, a guitar string winder, sustained industrial injury to her neck, right hand, right elbow, and right shoulder and resolved her case by Compromise and Release. Essential Interpreting (cost petitioner) sought payment for two interpreting service invoices—one for deposition preparation ($195.00) and one for review of the deposition transcript ($250.00). The WCJ found that cost petitioner was required to request a second bill review under Labor Code section 4603.2, which it failed to do, and deemed the lien satisfied. The Board granted reconsideration and rescinded the F&O, holding that the interpreting services were medical-legal expenses under section 4620 (not treatment-related services under section 4600/4603.2). The matter was returned to the WCJ to determine whether defendant timely served an EOR under section 4622(e)(1), which would determine whether cost petitioner needed to file an objection or a request for second bill review.