Verdeja, Luis

Cost petitioner Professional Interpreting, LLC provided Spanish translation services for applicant Luis Verdeja at the reading and signing of a Compromise and Release on November 21, 2022. It billed $350.00 (the market rate/Los Angeles County Superior Court rate) but defendant State Compensation Insurance Fund paid only $228.00, reducing payment under AD Rule 9795.3(b)(2). The WCJ found the services reasonable and necessary but limited recovery to Rule 9795.3(b)(2) and excluded Exhibits 4, 7, and 8 for lack of foundation. The WCAB granted reconsideration, holding that translation of a C&R for a non-English speaking worker is akin to an appeals board proceeding and is payable under AD Rule 9795.3(b)(1) at the greater of the Superior Court rate or market rate. The Board awarded an additional $122.00, admitted the three exhibits, and deferred the issue of costs, penalties, interest, sanctions, and attorney's fees.