Chang, Eva

Eva Chang sustained an admitted specific injury to the lumbar spine and a denied cumulative trauma injury to the right upper extremities, arm, and wrist. The WCJ issued a Joint F&A awarding PD benefits and future medical treatment but did not adjudicate an EDD lien claim for $29,291.71 in SDI benefits allegedly overlapping with PD benefits. Defendant Helmsman sought reconsideration arguing the award was defective for failing to address the EDD lien and prevent double recovery. The WCAB denied reconsideration, holding that the EDD lien was properly deferred because it was identified in the PTCS but never raised or adjudicated at trial, and must be tried separately. The Board corrected the WCJ's mistaken view that defendant would not be an 'aggrieved' party if the EDD lien were allowed, clarifying that defendant would be aggrieved if EDD obtained reimbursement from it.