MARIAM DAVTYAN vs. THE VONS COMPANIES, INC.
The Appeals Board granted the lien claimant's Petition for Removal, rescinding the WCJ's order for personal appearances by Dr. Collins and Paul Cohen and the Notice of Intent to impose sanctions. The Board found these orders prejudicial to the lien claimant's ability to present its case regarding the Medical Provider Network (MPN). While affirming the trial date, the Board clarified that the defendant bears the burden of proving the MPN's existence and validity. The decision emphasizes that sanctions should be considered after, not before, trial if appropriate.