Bonilla, Maria

Six lien claimants sought reconsideration of a WCJ's Joint F&O that found applicant Maria Bonilla did not sustain an industrial injury on May 2, 2008 and disallowed all six liens for failure to prove the treatment was reasonably required to cure or relieve effects of an industrial injury. The WCJ had disregarded AME Dr. Danzig's opinion as 'not stated in terms of reasonable medical probability.' The Board found no substantive difference between the WCJ's stated flaw and Dr. Danzig's actual opinion, which expressly found it 'medically probable' that 10% of applicant's back disability was due to the May 2, 2008 injury, and noted defendant had agreed in the C&Rs to pay future medical for that injury. The Board granted reconsideration, rescinded the Joint F&O, and substituted findings that applicant sustained injury on all three dates/periods, while deferring the lien recovery issues and returning the matter to the WCJ.