Grancich, William

Lien claimant Keystone Medical Group (Brent Pratley, M.D.), the authorized primary treating physician, filed a lien in ADJ8310173 but mistakenly listed the wrong case number, as the treatment related to the companion cumulative trauma case (ADJ9048241). The WCJ took the matter off calendar and issued a $2,905 cost order against the lien claimant, finding that the lien claimant failed to withdraw a lien filed in the wrong case despite being advised of the error. The WCAB rescinded both orders, finding that lien claimant had filed a timely objection to the notice of intention (which the WCJ erroneously found absent) and was entitled to a hearing on whether the case-number error could be cured. Applying longstanding principles of liberal pleading and adjudication on the merits, the Board held that a technical error in the case number was not a valid basis for dismissal or sanctions. The matter was remanded with instructions to consolidate the two cases and proceed to an MSC and, if necessary, trial on the reasonableness and necessity of the treatment.