Western Imaging Services, a copy service provider, last rendered services on February 12, 2014, but filed its lien claim and paid the activation fee on August 26, 2015—two weeks after the 18-month statute of limitations under Labor Code § 4903.5(a) expired on August 12, 2015. After failing to object to the defendant's DOR, failing to respond to the defendant's petition to take the lien conference off calendar, and failing to appear at the March 2, 2016 lien conference (which was taken off calendar), Western took no action until November 27, 2020, when it filed a Petition for Determination of Medical-Legal Expense Dispute seeking the same payment. The WCJ found that Western conceded its lien was time-barred and could not avoid the statute of limitations by the 'simple stratagem' of filing a Petition for Determination, relying on the en banc decision in Martinez v. Terrazas. The WCAB adopted and incorporated the WCJ's Report and denied reconsideration.
Issues
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Holding
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Analysis
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Applicant takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Defense takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Provider takeaway
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Similar decisions
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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