ALEKSEY VOLOSEVICH vs. SHANE ALEXANDER CUSTOM, INC., YORK RISK SERVICES GROUP, INC.
The Appeals Board reconsidered a WCJ's decision regarding a lien claim for interpreting services. While affirming the finding that the lien was not time-barred, the Board amended the order to clarify that the lien claimant is not entitled to Labor Code section 5814 penalties. Jurisdiction was reserved at the trial level to determine potential penalties under Labor Code section 4622 for services related to medical-legal evaluations. This amendment aligns with the principle that Section 5814 penalties are payable to the applicant, not the lien claimant, and were likely resolved by the applicant's Compromise and Release.