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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. ADJ9537329 ADJ9537436
Regular
Oct 10, 2019

LINDA RAMIREZ vs. PACIFIC ASIAN CONSORTIUM IN EMPLOYMENT, INC., CYPRESS INSURANCE COMPANY

This case involves a lien claimant, Med-Legal Photocopy, seeking reconsideration of a WCJ's decision that disallowed their lien for photocopy costs. The WCJ initially found no contested claim existed during the period the costs were incurred, thus invalidating the lien. However, the Appeals Board granted reconsideration, amending the F&O to find that a contested claim did exist during the period in question. Consequently, the lien of Med-Legal Photocopy is now deferred for further proceedings before the WCJ.

Workers' Compensation Appeals BoardLien ClaimantPetition for ReconsiderationFindings and OrderMedical-legal costsContested claimApplication for Adjudication of ClaimCompromise and ReleaseBurden of proofLabor Code
References
1
Case No. ADJ8229265, ADJ8782030
Regular
May 03, 2016

CHERYL TAGLAVORE vs. CONVENIENCE MANAGEMENT VALERO, ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board granted reconsideration for the lien claimant, Med-Legal Photocopy, after the WCJ disallowed its claims for photocopying services. The Board found that the WCJ erred in disallowing the lien, as the copying services were potentially incurred for the purpose of proving contested claims. The Board rescinded the WCJ's decision and returned the matter for further proceedings to determine the reasonableness and necessity of the photocopying costs for disputed issues. The Board emphasized that the existence of contested issues is not negated solely by an accepted injury, especially before a final disposition.

Lien ClaimantPhotocopying ServicesReconsiderationFindings of FactCompromise and ReleaseIndustrial InjuryLower ExtremitiesWCJMedical-Legal ExpenseContested Claim
References
5
Case No. ADJ7890528
Regular
Dec 09, 2013

RUBEN CRUZ vs. PACIFIC RIDGE FARMS, ZENITH INSURANCE COMPANY

This case concerns a defendant's petition for reconsideration of a prior decision that allowed a lien for photocopy services. The defendant argued the lien for duplicating already-obtained medical records was improperly allowed. The Appeals Board granted reconsideration, rescinded its prior order, and returned the matter to the trial level. This was because the Board found the photocopy expenses were not reasonably and necessarily incurred when the injury was admitted and the records were duplicative.

Med-Legal Photocopylien claimantPetition for ReconsiderationFindings and Orderrescindedmedical recordsLabor Code Section 4603.2medical-legal costsreimbursementapplicant's injury
References
5
Case No. ADJ6954999
Regular
Sep 01, 2015

VALENTIN GARCIA vs. KINGSBURG APPLE PACKERS, INC., ZENITH INSURANCE COMPANY

In this case, lien claimant Med-Legal Photocopy (MLP) sought reconsideration of a decision denying its claim for $\$ 3,827.05$ in photocopying expenses. The Appeals Board denied MLP's petition, finding that MLP failed to meet its burden of proof. Specifically, MLP did not demonstrate that a contested claim existed when the expenses were incurred, nor that they were necessary to prove or disprove such a claim. Therefore, the Board affirmed the denial of the lien.

References
3
Case No. ADJ1385972 (LBO 0378379)
Regular
Aug 01, 2013

AMELIA CUEVAS vs. IMAGINE FULFILLMENT SERVICES, EMPLOYERS COMPENSATION INSURANCE COMPANY

The Workers' Compensation Appeals Board granted reconsideration and rescinded an administrative law judge's order awarding costs to a lien claimant for photocopying services. The Board held that medical-legal expenses, including photocopying, are not recoverable under Labor Code section 5811. The original order was also deemed vague and potentially void for not clearly defining the parties' rights and obligations. The case is returned to the trial level for further proceedings.

Workers' Compensation Appeals BoardLabor Code §5811Petition for CostsLien ClaimantPhotocopying ServicesMedical-Legal ExpensesReconsiderationWCJ OrderRescindedTimeliness of Petition
References
6
Case No. ADJ8752588
Regular
Dec 20, 2017

HUMBERTO LOPEZ vs. LANCASTER BURNS CONSTRUCTION COMPANY, ZURICH INSURANCE GROUP LTD./ZURICH NORTH AMERICAN INSURANCE COMPANY

This case involves a lien claim by Med Legal Photocopy for services rendered in connection with applicant Humberto Lopez's workers' compensation claim. The initial judge denied the lien, finding the photocopy charges unreasonable. However, the Appeals Board granted reconsideration, finding the defendant waived objections to reasonableness by failing to provide a timely explanation of review. Consequently, the lien was allowed in full, with a 10% increase due to delayed payment, plus interest and reimbursement of the filing fee.

Med Legal PhotocopyLancaster Burns ConstructionZurich Insurance GroupPetition for ReconsiderationFindings and Orderstatute of limitationsburden of proofreasonable chargeslien denialwaiver of objection
References
5
Case No. ADJ8064878
Regular
Aug 07, 2018

LATASHA WOODSON vs. COUNTY OF RIVERSIDE

This case involves a lien claimant, Western Imaging Services, seeking payment for copying services. The original judge disallowed the lien, finding the services duplicative and unnecessary, and that the claimant was not a licensed professional photocopier. The Appeals Board rescinded this decision, remanding the case for further proceedings. Key issues to be re-examined include the timeliness and specificity of the defendant's objections to the lien claimant's invoices, and whether the claimant is exempt from professional photocopier registration due to their independent contractor status with the applicant's attorney.

Workers' Compensation Appeals BoardReconsiderationLien ClaimantDuplicative ServicesUnnecessary ServicesLicensed Professional PhotocopierAdministrative Law JudgeContested ClaimMedical-Legal ExpensesLabor Code
References
14
Case No. ADJ7375307
Regular
Dec 06, 2016

REYNA VALDEZ vs. FULL CIRCLE DAIRY, ZENITH INSURANCE COMPANY

In this workers' compensation case, the Appeals Board granted reconsideration and rescinded the lower court's decision denying a lien claimant's claim for photocopy services. The Board found insufficient evidence to determine if a "contested claim" existed at the time the services were rendered, which is a prerequisite for reimbursement of medical-legal expenses. The matter was returned to the trial level for further proceedings and a new decision on the existence of a contested claim. The Board clarified that obtaining records via subpoena is permissible and that photocopy fees are considered recoverable medical-legal expenses if a contested claim is established.

Workers' Compensation Appeals BoardReyna ValdezFull Circle DairyZenith Insurance CompanyADJ7375307Opinion and Decision After ReconsiderationMed Legal Photocopylien claimantFindings and Ordercontested claim
References
8
Case No. ADJ8912546
Regular
Jan 19, 2016

CARLOS CASTRO, CARLOS CASTRO VICENTE vs. MURANAKA FARMS, ZENITH INSURANCE COMPANY

This case involves a lien claim by Western Imaging Services for photocopying services rendered to applicant's attorney. The Workers' Compensation Appeals Board (WCAB) granted reconsideration, rescinding the initial findings. The WCAB held that Western Imaging Services is exempt from professional photocopier registration requirements under Business and Professions Code section 22451(b) because it acted as an independent contractor for the applicant's attorney, a member of the State Bar. The WCAB also admitted the attorney's letter confirming this independent contractor status into evidence, finding it substantial evidence for Western's claim.

Professional photocopierBusiness and Professions Code section 22451Independent contractorMember of the State BarLien claimantPetition for reconsiderationPetition for removalWCJ reportCompromise and ReleaseMedical-legal expenses
References
9
Case No. ADJ9351964 ADJ9351965
Regular
Apr 13, 2016

ROGELIO CORNEJO vs. YOUNIQUE CAFE INC., ZENITH INSURANCE COMPANY

The Workers' Compensation Appeals Board affirmed its prior decision, holding that Business and Professions Code section 22451(b) exempts agents and independent contractors of attorneys from registration requirements for photocopying services, even when compensated. This exemption applies to lien claimants like Western Imaging Services, Inc., when they act as authorized representatives of an attorney. The Board rejected the defendant's argument that the exemption should be narrowly construed to exclude compensated photocopiers. Therefore, proof of compliance with registration and bonding provisions was not required for the lien claimant to recover copy service fees.

Workers' Compensation Appeals BoardYounique Cafe Inc.Zenith Insurance CompanyWestern Imaging Services Inc.Rogelio CornejoMedical-Legal ExpensesLabor Code Section 4620(a)Business and Professions Code Chapter 20Business and Professions Code Section 22451(b)Agent
References
9
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