DORA FLORES vs. ABM INDUSTRIES, INC., Permissibly Self-Insured, Administered By ACE-USA/ESIS

The Workers' Compensation Appeals Board granted reconsideration to rescind sanctions against lien claimant Global Interpreting. While Global Interpreting's lien was disallowed for failure to prove the reasonableness and necessity of its interpreter services due to inadmissible evidence, the Board found no frivolous conduct warranting sanctions. The WCJ improperly excluded evidence presented after a lien conference where the lien claimant was ordered to serve evidence, leading to potential confusion regarding due process.