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The Appeals Board granted reconsideration to Sepulveda Plaza Medical Center, Inc. (Sepulveda), a lien claimant, reversing the WCJ's decision. The Board found the WCJ improperly applied a new statute of limitations retroactively to Sepulveda's lien filed in 2012. Furthermore, the Board determined the WCJ erred by not fully addressing Sepulveda's burden of proof regarding the reasonableness and necessity of treatment under Labor Code § 5402(c). The case is returned to the trial level for further proceedings on the timeliness of the lien filing and Sepulveda's proof of entitlement.
Full Decision Text1 Pages
The Appeals Board granted reconsideration to Sepulveda Plaza Medical Center, Inc. (Sepulveda), a lien claimant, reversing the WCJ's decision. The Board found the WCJ improperly applied a new statute of limitations retroactively to Sepulveda's lien filed in 2012. Furthermore, the Board determined the WCJ erred by not fully addressing Sepulveda's burden of proof regarding the reasonableness and necessity of treatment under Labor Code § 5402(c). The case is returned to the trial level for further proceedings on the timeliness of the lien filing and Sepulveda's proof of entitlement.
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