Cristina Sosa — ADJ9182040

Copy service provider Supreme Copy Service sought reconsideration of a May 27, 2026 F&O in which the WCJ held it was not a valid cost petitioner and must instead pursue reimbursement of its copy service charges as a lien claimant subject to lien filing fees and statute of limitations. The Board granted reconsideration, rescinded the F&O, and held that WCAB Rule 10545 does not apply to disputes involving medical-legal charges because such expenses are specifically allowable as liens under Labor Code section 4903. The Board found copy service fees are medical-legal expenses under section 4620(a) and that a medical-legal provider has a dual remedy: filing a lien under section 4903(b) or utilizing the dispute resolution procedures of WCAB Rule 10786. Supreme Copy was permitted to pursue reimbursement via the Rule 10786 procedures, and the matter was returned to the trial level for further proceedings without any opinion on the merits.