Wonda Brazile Traylor — ADJ9873183

Lien claimant Med-Legal Photocopy sought reimbursement for copy services (invoice #1313134) provided in connection with a subpoena duces tecum served on the employer in April 2015, before the July 1, 2015 effective date of the Copy Service Fee Schedule. The WCJ found defendant failed to timely pay the undisputed amount and was liable for the reasonable value of the services, calculated at 89.3% of the billed amount ($1,179.45) based on defendant's historical payment patterns to this lien claimant, plus penalties and interest under Labor Code §4622(a)(1). Because the services predated the fee schedule, the WCJ held the schedule did not control and the lien claimant met its burden of proving reasonable value through evidence of prior charges and payments. The WCAB adopted the WCJ's report and denied reconsideration. The Board confirmed that where no fee schedule applies, the lien claimant must present evidence of reasonable value, which Med-Legal satisfied.