Alberdin, Eduardo

Med-1 Medical Center, Inc., a lien claimant subject to a 15-year stay (2005-2020) on its liens, was ordered on January 21, 2020 by WCJ Crawford to file all remaining liens within 30 days (by February 20, 2020). Med-1 filed a timely January 31, 2020 letter seeking an extension to April 10, 2020, but the WCJ treated the letter as improper, refused to transmit it to the Appeals Board, and set the matter for trial, ultimately finding no good cause to relieve Med-1 from the order. On reconsideration, the Appeals Board found the January 31, 2020 letter was effectively a petition for removal that should have been transmitted to the Board rather than rejected for form defects, and that good cause existed to extend the filing deadline to June 9, 2020. The Board rescinded the F&O and substituted new findings recognizing good cause, citing due process rights, the COVID-19 shutdown, and the policy favoring hearings on the merits. A subsequent petition for reconsideration by SCIF of that April 22, 2024 decision was denied on November 4, 2024.