Eloisa Becerra Quezada — ADJ12140628, ADJ13210903

Defendant Marriott International sought reconsideration of a WCJ order imposing $750 in sanctions to the General Fund and $165 in costs to interpreting cost petitioner Dolores Campos Interpreting Services for unreasonable delay in paying a $300 interpreting invoice. The cost petitioner served its invoice on December 20, 2019, but defendant did not pay until August 19, 2020, after the cost petitioner filed a Petition for Costs. Defendant argued it never received the invoice and was denied due process. The Board found defendant received adequate notice and opportunity to be heard, and that its declarations failed to rebut the Evidence Code section 641 presumption of receipt of mailed documents under the Suon standard. The Board affirmed the sanctions order but reduced the General Fund sanction from $750 to $125, finding the higher amount excessive given defendant's prompt payment once it received the Petition for Costs, while affirming the $165 cost award.