CompFox AI Summary
The Workers' Compensation Appeals Board (WCAB) granted reconsideration of a prior decision by a workers' compensation administrative law judge (WCJ) concerning lien claimants Industrial Healthcare PMG, Complete Interpreting, and Peralta Hills-Mission Valley Imaging. The WCJ had dismissed their liens, finding their declarations under Labor Code section 4903.8(d) invalid. The WCAB, however, found that the declarant, Ilona Kulikova, possessed sufficient personal knowledge and access to information to competently testify regarding the services provided and billing accuracy. Consequently, the WCAB rescinded the WCJ's Findings and Orders and substituted new findings declaring the lien claimants' original section 4903.8(d) declarations valid, thus remanding the matter for further proceedings.
Full Decision Text1 Pages
The Workers' Compensation Appeals Board (WCAB) granted reconsideration of a prior decision by a workers' compensation administrative law judge (WCJ) concerning lien claimants Industrial Healthcare PMG, Complete Interpreting, and Peralta Hills-Mission Valley Imaging. The WCJ had dismissed their liens, finding their declarations under Labor Code section 4903.8(d) invalid. The WCAB, however, found that the declarant, Ilona Kulikova, possessed sufficient personal knowledge and access to information to competently testify regarding the services provided and billing accuracy. Consequently, the WCAB rescinded the WCJ's Findings and Orders and substituted new findings declaring the lien claimants' original section 4903.8(d) declarations valid, thus remanding the matter for further proceedings.
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