VINCENTE CARDENAS vs. VTL AMPLIFIERS, CALIFORNIA INSURANCE GUARANTEE ASSOCIATION, ITS SERVICING FACILITY BROADSPIRE, A CRAWFORD COMPANY, FOR CALIFORNIA COMPENSATION IN LIQUIDATION

The Workers' Compensation Appeals Board granted reconsideration and rescinded a prior decision that barred lien claimant Dr. Elena Konstat's claim. The WCAB found that the statute of limitations did not apply because the services were provided before the relevant amendment, and the lien claimant's filing date was timely under the then-existing statute. Furthermore, the WCAB determined that the statute of limitations was tolled because the defendant failed to serve the lien claimant with the approved Compromise and Release, as required by WCAB Rule 10886. The case was returned to the trial level for further proceedings and a new decision.