WCPanelIQ
PanelMed-legalLienGranted

Margarita Garcia — ADJ9213906, ADJ9920273

MARGARITA GARCIA, Applicant vs. CR LAURENCE COMPANY, INC.; CHUBB GROUP OF INSURANCE COMPANIES, administered by SEDGWICK CLAIMS MANAGEMENT SERVICES, INC., Defendants

ADJ number
ADJ9213906, ADJ9920273
Decision date
Aug 10, 2026
District office
Van Nuys
WCJ
—
Claim administrator
Sedgwick Claims Management Services, Inc. (administering Chubb Group of Insurance Companies)
Commissioners
KATHERINE WILLIAMS DODD, COMMISSIONER, CRAIG L. SNELLINGS, COMMISSIONER, JOSEPH V. CAPURRO, COMMISSIONER
LC §3205.5LC §4603.3LC §4603.6LC §4620LC §4621LC §4622LC §5307.9LC §5312LC §5705.5LC §5708LC §5709LC §5813LC §5900LC §5909CCR §9794CCR §9982CCR §10330CCR §10421CCR §10786

Summary

Supreme Copy Service, a copy service cost petitioner, sought reconsideration of a WCJ's Findings of Fact and Orders that referred its subpoena/records bills to bill review for payment per the copy service fee schedule under section 4622. The WCAB granted reconsideration, holding that because defendant offered no evidence it issued timely, compliant objections or EORs to the invoices within the statutory 60-day window, defendant waived all objections other than compliance with sections 4620 and 4621. As a result, the fee schedule does not apply, and cost petitioner is entitled to the reasonable value of services plus a 10 percent penalty and 7 percent per annum interest under section 4622(a) and WCAB Rule 10786(e). The Board also admitted all of cost petitioner's Exhibits 32-36 into evidence, reversing the WCJ's recommended exclusion of Exhibits 34 and 35. The issue of bad-faith sanctions, attorney's fees, and costs under WCAB Rule 10786(i) was deferred and returned to the WCJ.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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