Stipulation Effective Upon Execution - Penalties Accrue For Late Payment Even When WCJ Approval is Pending

G. Varkey v. WCAB (Cardone Industries & Fireman Fund)is a case rather limited to its facts, but the Commonwealth Court did reverse the Board and find a penalty and attorney's fees were due on late payment under a stipulation, even though the WCJ had not issued his decision approving the stipulation when the late payment was made.