Richard Martinez vs. SIFLING BROTHERS, ZENITH INSURANCE COMPANY
Lien claimants, Dr. Silver and Dr. Bresler, sought payment for medical services exceeding the Official Medical Fee Schedule (OMFS). They argued their services warranted higher fees due to "extraordinary circumstances" and defendant's alleged improper billing practices. The Workers' Compensation Appeals Board denied their petitions for reconsideration, finding they failed to meet the burden of proof. The board held that lien claimants must demonstrate extraordinary circumstances justifying fees above the OMFS and present evidence of their usual and customary fees.