Avolevan, Marina

Applicant, a nurse technician, claimed a cumulative trauma injury to her right knee from July 18, 2003 to July 18, 2013 against permissibly self-insured Antelope Valley Hospital. The WCJ found industrial injury AOE/COE and that compensation was not barred by section 5412. Defendant sought reconsideration, arguing the evidence did not support a cumulative trauma, that no treating physician identified an industrial injury, and that any injury arose from 'normal bodily movements.' The Board affirmed, relying on the QME's opinion that work activities contributed at least one percent to the injury and finding the 'normal bodily movements' defense unavailing under California law. The Board amended the F&A only to add a finding that the date of injury under section 5412 was July 1, 2015, when applicant met with counsel and filed the claim, which fixed the concurrence of knowledge and disability within the limitations period.