Amalia Hernandez — ADJ10371658

A cost petitioner (interpreter) sought reconsideration of a WCJ's Findings and Order that awarded payment for interpreting services rendered for translation of a Compromise and Release under AD Rule 9795.3(b)(1), but denied sanctions and attorney fees, finding defendant's denial of liability was not the result of bad-faith or frivolous tactics. The WCAB affirmed, agreeing that due process requires interpreting services for translation of a C&R for non-English speaking workers and that such services are payable under AD Rule 9795.3(b)(1). However, the Board held the WCJ did not abuse his discretion in declining to impose sanctions because reasonable ambiguities existed in the law regarding whether settlement interpreting costs were compensable and at what rate. The Board affirmed the F&O in full.