Darin Day vs. CITY OF LOS ANGELES, TRISTAR
The Workers' Compensation Appeals Board affirmed a prior decision allowing a medical lien by VQ Orthocare against the City of Los Angeles. The Board found VQ's lien was valid despite late filing of a required declaration, as the lien was filed before the relevant statute's effective date. Defendant's arguments regarding the timeliness and form of the declaration were rejected, with the Board noting compliance with procedural rules for electronic filing and declarations under penalty of perjury. The lien was thus permitted to proceed on its merits.