Luis Sepulveda — ADJ14513544

Applicant Luis Sepulveda claimed a specific injury to multiple body parts while employed by Kentucky Fried Chicken; the case in chief settled by compromise and release approved October 6, 2022, leaving lien issues pending. After defendant Zurich (represented by Manning Kass) allegedly failed to appear at lien conferences on February 21 and March 21, 2023, the WCJ issued a Notice of Intention to Sanction and then a $1,000 sanction order on May 3, 2023 under Labor Code section 5813. Zurich sought reconsideration, arguing it had counsel, was not required to attend lien hearings, did not act in bad faith, and was entitled to a hearing. The Board rescinded the sanction order, finding Zurich was denied adequate notice and a meaningful opportunity to be heard, that reliance on unchecked appearance boxes was insufficient evidence of non-appearance, and that no evidentiary record supported the sanction. The matter was returned to the trial level for further proceedings.