Matter of Fernandez v. Royal Coach Lines, Inc.
Claimant's counsel appealed a decision by the Workers’ Compensation Board that reduced their previously awarded counsel fees from $2,800 to $450. The Board found the counsel's fee application, form OC-400.1, deficient as it failed to provide specific dates and time spent for each service, as mandated by 12 NYCRR 300.17 (d) and Board bulletin Subject Number 046-548. Additionally, counsel failed to disclose a prior $900 fee award. The Appellate Division affirmed the Board's decision, holding that the Board did not abuse its discretion in reducing the fees due to the non-compliant application. The court also clarified that prior holdings suggesting no requirement for time spent on services, such as in *Matter of Pavone*, should no longer be followed.