LEOPOLDO SIMOTA vs. AMERICAN NURSERIES, VIRGINIA SURETY, APPLIED RISK SERVICES

The Workers' Compensation Appeals Board denied the lien claimant's petition for reconsideration, upholding the administrative law judge's decision to disallow the lien. The lien claimant argued they had submitted sufficient evidence via EAMS, but the Board clarified that filing in EAMS does not equate to submitting admissible evidence for evaluation. The Board emphasized that proper evidentiary procedures must be followed, citing due process and fundamental rules of evidence submission. Consequently, the lien claimant's failure to properly present evidence led to the denial of their petition.