Ortiz, Marco

Cost petitioner Tony Barriere Interpreting Service, Inc., through attorney George Corson, sought reconsideration of a June 16, 2025 Joint Findings and Order that denied its claim for attorney's fees and sanctions arising from a dispute over interpreter payment. The interpreter had billed for services connected to a C&R reading and deposition preparation; defendant paid the $266.00 rate requested plus a self-imposed penalty of $50.47 before trial. The cost petitioner nevertheless pursued attorney's fees of $4,545.00 and sanctions, alleging unreasonable delay and bad faith, and sought an adverse inference based on defendant's objection to a Notice to Produce. The WCJ found the cost petitioner failed to meet its burden of proving bad faith, that discovery was moot since the bill was already paid, and that no discovery order had been violated. The WCAB adopted the WCJ's Report and Opinion, added that sanctions under Rule 10545(h) still require a finding of bad faith under Labor Code section 5813, and denied reconsideration.