Martinez, Juan

Lien collection agency Angoal Medical Collections (AMC) sought reconsideration of a WCJ's February 13, 2020 decision disallowing AMC's lien (assigned by Julie Goalwin, M.D.) and dismissing the lien of Alan Rosenthal, D.C. Both providers had performed medical-legal evaluations in 2003 and assigned their interests to AMC, which filed the underlying liens in early 2004 but did not file the purchase agreements until May 22, 2019. The WCAB held that although filing and service of the assignments were untimely, nothing in Labor Code section 4903.8 invalidates the liens, and the defense of laches failed because defendant produced no affirmative evidence of prejudice from the delay. The Board rescinded the F&O and substituted new findings that the liens were not barred by laches.