MOLLY PANIAGUA vs. FISHER FARMS, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION, Adjusted By BROADSPIRE for SUPERIOR NATIONAL, In Liquidation, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION, Adjusted By INTERCARE INSURANCE for PAULA INSURANCE, In Liquidation

The Workers' Compensation Appeals Board granted reconsideration and affirmed the WCJ's finding of unreasonable delay in permanent disability payments by the defendant. While initially a 25% penalty was awarded, the Board reduced it to 10% as recommended by the WCJ, acknowledging a reasonable legal doubt regarding the start date of benefits prior to a specific WCJ decision. The Board also affirmed the denial of the defendant's credit for prior payments and the imposition of penalties for unilateral credit-taking and attorney fees.