Olivas, David

Spanish-language interpreter Marjorie Martinez provided interpreting services for the reading of a Compromise and Release settlement document to applicant David Olivas on May 19, 2021, billing $350.00, which was served on defendant in October and November 2023. Defendant denied liability arguing the bill was untimely under Labor Code section 4603.2(b), which requires submission within 12 months of the date of service. The WCJ found that section 4603.2(b) applies only to services provided pursuant to section 4600 (medical treatment), and that interpreting for a C&R reading falls outside that context, making it recoverable via a Petition for Costs under CCR section 10545, which has no 12-month billing deadline. The Appeals Board adopted the WCJ's Report and Opinion, denied reconsideration, and admonished defendant's non-attorney representative for citing inapplicable caselaw (Dorsett) in what it characterized as a frivolous attempt to mislead the Board.