SILVIA ESTRADA vs. TAMTAM MEDICAL GROUP, INC., PREFERRED EMPLOYERS INSURANCE COMPANY

This case involves a lien claimant, Southland Spine & Rehabilitation, seeking reconsideration of a denial of its lien. The Workers' Compensation Appeals Board (WCAB) denied reconsideration, upholding the finding that Southland's lien was barred. The WCJ previously ruled that the applicant's claim was resolved by a compromise and release and was barred as a post-termination claim, making the lien derivative and therefore also barred. The WCAB found that Southland failed to establish industrial injury AOE/COE by a preponderance of evidence and that this issue was waived by not being raised earlier.