Fish v. Extreme Enterprises of Marion County, Inc.
A catastrophically brain-injured worker's mother was ordered by the JCC to obtain a circuit-court guardianship so chapter 440 proceedings could continue; the JCC then denied reimbursement of the guardianship filing fees, examining-committee costs, and guardianship counsel's fee on the theory that those services were not rendered in the workers' compensation proceeding. The First DCA set the order aside, clarifying that reimbursable expenses are those 'inherently linked' to the workers' compensation case and required to pursue benefits, even if performed outside a formal chapter 440 proceeding.
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