FRIEDMAN, Judge.
The School District of Philadelphia (Employer) appeals from the January 21, 1998 order of the Workers' Compensation Appeal Board (WCAB) affirming, as modified, the January 22, 1996 decision of the Workers' Compensation Judge (WCJ) to grant Griffin Washington's (Claimant) penalty petition and to assess counsel fees against Employer under section 440 of the Workers' Compensation Act (Act).
On October 18, 1991, Claimant...
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