Home/Case Law/VICTOR SANTOYO vs. WEST CENTRAL PRODUCE, ZENITH INSURANCE COMPANY
Regular DecisionReconsideration

VICTOR SANTOYO vs. WEST CENTRAL PRODUCE, ZENITH INSURANCE COMPANY

Filed: Sep 28, 2018
Los Angeles
ADJ8060110, ADJ8060106

CompFox AI Summary

The Workers' Compensation Appeals Board denied reconsideration of a lien claim for medical-legal expenses. The claimant failed to prove a contested claim existed at the time the expenses were incurred, a prerequisite for employer liability under Labor Code sections 4620 and 4621. Copy service fees for medical records are considered medical-legal expenses, but the claimant bore the burden of proving their necessity and the existence of a contested claim. The Board adopted the WCJ's report, excluding discussion on the "existence of contested claim" from their specific reasoning.

Full Decision Text1 Pages

The Workers' Compensation Appeals Board denied reconsideration of a lien claim for medical-legal expenses. The claimant failed to prove a contested claim existed at the time the expenses were incurred, a prerequisite for employer liability under Labor Code sections 4620 and 4621. Copy service fees for medical records are considered medical-legal expenses, but the claimant bore the burden of proving their necessity and the existence of a contested claim. The Board adopted the WCJ's report, excluding discussion on the "existence of contested claim" from their specific reasoning.

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