Magana, Pascual

Cost petitioner Document Analyst Group, Inc. issued a subpoena duces tecum on February 10, 2023 (served February 13, 2023) at applicant's attorney's request and sought reimbursement of $230.00 as a medical-legal/copy service expense, plus penalties, interest, costs, sanctions, and attorney fees. The WCJ found that on the date of service 'there were no contested issues,' but nonetheless found the services and amount reasonable and ordered the record developed on costs, sanctions, and fees. Defendant sought reconsideration, contending the claim was not contested under section 4620 and therefore services were not reasonable or necessary. The Appeals Board disagreed with the WCJ's narrow construction of 'contested issues,' holding that a contested claim existed because defendant continued to dispute other body parts, temporary disability, and permanent disability even after accepting two body parts. The Board granted reconsideration, amended Finding of Fact 3 to find a contested claim existed under Labor Code section 4620, and otherwise affirmed the F&O.