MARY PENA vs. FRITO LAY, ACE AMERICAN INSURANCE

This case concerns the dismissal of liens for failure to timely pay activation fees. The defendant argued that liens from Vasquez Vocational Experts and JAM Medical Equipment should have been dismissed at a lien conference due to non-payment of the activation fee prior to the scheduled conference. While the WCJ did not dismiss the liens, the Appeals Board granted the defendant's petition for removal. The Board found that both lien claimants failed to comply with Labor Code section 4903.06(a)(4), as JAM paid after the conference began and Vasquez paid months later. Consequently, the liens of Vasquez Vocational Experts and JAM Medical Equipment were dismissed with prejudice.