Papp, Lajos

Applicant Lajos Papp sought reconsideration of a December 12, 2024 Findings of Fact and Orders that found no industrial injury based on the PQME reporting of Dr. Nicole Chitnis. The WCJ had excluded applicant's self-procured Exhibit 2 (a PR-4 from chiropractor Michael Clark) and relied on Dr. Chitnis's causation opinion finding applicant's back condition stemmed from a non-industrial 2015 lifting injury. The Appeals Board granted reconsideration solely to admit Exhibit 2, citing Valdez v. WCAB for the expansive admissibility of medical evidence, but otherwise affirmed the WCJ. The Board upheld the WCJ's finding that Dr. Chitnis's reporting constituted substantial medical evidence and gave great weight to the WCJ's credibility determination rejecting applicant's claim that Dr. Chitnis spent less than 30 minutes during evaluations. The decision also addressed the timeliness of the petition under amended Labor Code section 5909.