Kang, Am

Defendant Star Insurance Company (c/o Illinois Midwest) sought reconsideration of a WCJ's October 17, 2023 Findings and Order finding in favor of lien claimant California Imaging Solutions (San Diego Imaging) for copy/subpoena services. Defendant argued the lien claimant performed subpoena services on November 27 and December 3, 2013, after discovery had closed by operation of law on July 15, 2013. The WCAB denied reconsideration, adopting the WCJ's Report and additionally invoking its broad equitable powers. The Board reasoned that although the subpoenas were served during a brief window when discovery was technically closed, the Court of Appeal subsequently annulled the underlying decision (at defendant's behest) and remanded for development of the record, requiring the same records to be provided to evaluating physicians—making the subpoena services an inevitability and equitably compensable. The Board also noted the defendant's Explanations of Review were untimely and deficient.