Salazar, Juan

Lien claimants Industrial Healthcare PMG, Complete Interpreting, and Peralta Hills-Mission Valley Imaging filed liens supported by Labor Code section 4903.8(d) declarations signed by Ilona Kulikova. The WCJ initially found the declarations invalid because Kulikova lacked personal knowledge of the services provided and relied on information entered into a computer system by others, and that amended declarations were untimely. On reconsideration, the WCAB issued an ODAR finding the declarations valid because they complied with CCP section 2015.5 and made a prima facie showing of truth, shifting the burden to defendant to prove incompetence. Defendant sought further reconsideration, arguing the declarant was not competent because she lacked direct knowledge of the physicians' services. The Board denied reconsideration, holding that section 4903.8(d) does not require firsthand or percipient knowledge and that defendant offered no persuasive evidence to overcome the prima facie showing.