Eduardo Olvera — ADJ18902547, ADJ18901822

Defendant sought removal of a Joint Findings, Award, and Orders in which the WCJ found that the defendant unreasonably delayed payment of a certified interpreter's invoice ($460 total for deposition preparation and C&R reading services), that sanctions in the form of attorney fees were warranted, that the defendant conducted discovery in bad faith, and that the cost petitioner had established market rate. The WCAB treated the Petition for Removal as a Petition for Reconsideration because the F&A contained final findings (the sanctions/attorney fee award), not merely interlocutory rulings. Adopting the WCJ's Report, the Board found the defendant paid the interpreter over a year after service of billing with no timely objection, violating CCR 9795.4's 60-day requirement, and objected to nearly all discovery requests without a privilege log or good-faith response. The Board concluded the cost petitioner met its burden on market rate and that the burden shifted to defendant, who failed to rebut it. The Petition was denied.