WCPanelIQ
PanelMed-legalLienGranted

Sanchez, Flavio

FLAVIO SANCHEZ, Applicant vs. REHRIG PACIFIC COMPANY; U. S. FIRE INSURANCE, administered by ZENITH INSURANCE, Defendants

ADJ number
ADJ7966725
Decision date
Aug 21, 2024
District office
Van Nuys
WCJ
—
Claim administrator
Zenith Insurance (administering for U.S. Fire Insurance)
Commissioners
CRAIG SNELLINGS, COMMISSIONER, JOSEPH V. CAPURRO, COMMISSIONER, JOSÉ H. RAZO, COMMISSIONER
LC §4620LC §4621LC §4622LC §4900LC §5701LC §5803LC §5901LC §5903LC §5906LC §5907LC §5908LC §5908.5LC §5950LC §5952CCR §10530CCR §10786

Summary

Platinum Copy, Inc. (PCI), a copy service lien claimant, sought reconsideration of a WCJ's May 30, 2024 Findings, Award and Order. The WCJ awarded PCI payment plus penalties and interest for records obtained from two medical providers but denied reimbursement for records subpoenaed from applicant's prior attorney, Robin Jacobs, Esq., reasoning that obtaining a prior attorney's file is an office expense rather than a medical-legal cost because the prior attorney is required to turn over the file. PCI argued there is no requirement that new counsel first seek records by informal written release before subpoenaing them, citing Lopez v. Lauramark Enterprises. The Appeals Board granted reconsideration based on its preliminary review, finding it unclear whether the legal issues were properly identified and whether the record was sufficient to support the WCJ's conclusions. The Board deferred a final decision pending further review of the merits and the entire record.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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