Serrano, Gladys

Cost petitioner Platinum Copy sought reconsideration of a May 19, 2025 F&O in which the WCJ granted defendant's motion to quash and found the copy service failed to meet its burden to recover medical-legal costs, ordering it take nothing on its petitions for costs and sanctions. The dispute centered on copy service charges for subpoenas of medical records, the former applicant attorney's litigation file, and LAUSD HR records, none of which were served on defense counsel who had been a party since 2021. The Board found a contested claim existed under section 4620, but held cost petitioner failed its burden under section 4621 to prove the charges were reasonable, actually, and necessarily incurred—particularly because defendant had already provided the medical records the same day the new attorney requested them. The Board denied reconsideration, declining to reach the defective service issue because the failure to establish reasonableness was independent grounds to deny payment.