California, United States of America
The following excerpt is from Fidelity & Cas. Co. of New York v. Workers' Comp. Appeals Bd., 141 Cal.Rptr. 925, 75 Cal.App.3d 192 (Cal. App. 1977):
Relying on Adams, supra, the court in Sierra Pac. Industries v. Workers' Comp. Appeals Bd., supra, 67 Cal.App.3d 413, held that a penalty applied to the entire award even though only the attorney's fees had been unreasonably delayed.
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