CELSO PALOS vs. BAUMANN ENGINEERING, BERKSHIRE HATHAWAY
The lien claimant, Labs for Physicians & Surgeons, sought removal of an EAMS notation dismissing its lien by operation of law due to a clerical error in filing a required declaration. The Appeals Board vacated its prior grant of reconsideration and dismissed the petition for removal. This decision allows the lien claimant to seek relief at the trial level, where a WCJ can determine if there's good cause to correct the error and remove the dismissal notation. The Board emphasized due process rights, including the right to a hearing on whether the dismissal should be set aside due to mistake or excusable neglect.