JOYCE GENHO vs. NEW HORIZON LEARNING CENTER, STATE COMPENSATION INSURANCE FUND
This case involves an applicant who sustained industrial injury to both upper extremities. The Appeals Board affirmed the WCJ's decision, finding that the applicant's permanent disability should be rated using the 1997 Schedule, not the 2005 Schedule, due to pre-2005 medical evidence indicating permanent disability. The Board found Dr. Buchwald's April 14, 2003 report admissible despite a minor defect, as it was cured by a later report containing the required declaration. Finally, the Board rejected the defendant's claim of newly discovered evidence, finding their petition lacked the required specificity.