NORINA CLEMENTE vs. CALIFORNIA STATE UNIVERSITY DOMINGUEZ HILLS, Permissibly Self-Insured and Administered By SEDGWICK CLAIMS MANAGEMENT SERVICES

This case involves a lien claimant, Physical Rehabilitation Services, petitioning for reconsideration of a WCJ's finding of bad faith under Labor Code section 5813. The WCJ had previously ordered the defendant to itemize litigation costs incurred due to the lien claimant's alleged frivolous actions. The WCAB granted reconsideration, rescinded the original F&O, and returned the matter to the WCJ for further proceedings. This decision was based on the WCJ's own report recommending further record development.