Guadalupe Gastelum — ADJ9098027

Applicant Guadalupe Gastelum sought reconsideration of a July 7, 2026 F&O finding no unreasonable delay and no violation of Labor Code sections 5800, 5814, or 5814.5 regarding a $19,500 attorney's fee check issued under a Compromise and Release. The original check was issued timely on October 31, 2024 (eight days after the OACR), but was returned to sender as undeliverable, and a replacement was reissued December 3, 2024. The Board affirmed the WCJ's finding that the delay was not unreasonable, inadvertent, promptly corrected, and partly attributable to applicant's attorney's slow responses. However, the Board amended the F&O to defer the issue of interest under section 5800, holding that interest is mandatory and cannot be entirely waived by stipulation, while encouraging the parties to resolve the small sum amicably. The Petition was granted only to the extent of deferring the interest issue, with the remainder of the F&O affirmed.