Doran, Theresa

Applicant Theresa Doran filed a cumulative trauma claim for injuries to her shoulders, arm, and wrist during employment with Lam Research Corporation. Defendant SNCC, administered by Tristar Risk Management, issued two SDTs to Solano Primary Care Medical Group and John Muir Health seeking all of applicant's medical records, and applicant petitioned to quash. The WCJ issued an October 29, 2024 Order limiting the SDTs to records solely related to applicant's upper extremities, citing 'good cause' but providing no supporting reasoning or evidentiary basis. Defendant sought removal, arguing the limitation foreclosed its liberal right to discovery. The Appeals Board granted removal, rescinded the WCJ's Order because the WCJ failed to articulate the basis for the good cause finding or the evidence relied upon, and remanded for a status conference to determine what discovery is necessary.