WILBERT SPRY vs. SAFEWAY/SAFEWAY, INC.
The Workers' Compensation Appeals Board denied Safeway's petition for removal, which sought to quash a second subpoena for medical records. The Board found that Safeway failed to demonstrate irreparable harm or substantial prejudice, and that reconsideration would be an adequate remedy. The Board also noted that workers' compensation proceedings are governed by the Labor Code, not the Code of Civil Procedure.