Cortes, Jose

Jose Cortes, a receiving clerk, had three related claims involving right, left, and bilateral shoulder injuries that were accepted by his self-insured employer. After a trial, the WCJ issued a Joint Findings, Award, and Orders on 2/21/23 awarding temporary disability for 9/29/20 through 3/15/21 in the cumulative trauma claim (ADJ10713342). Defendant petitioned for reconsideration, asserting it was entitled to credit for temporary disability it allegedly paid in the companion specific-injury claim (ADJ10713340) for an overlapping period. The WCJ recommended denial because Defendant failed to raise the credit issue on the Pre-Trial Conference Statement, failed to present any evidence (no benefit printout) that the payments were actually made, and failed to enter a stipulation regarding prior payments. The WCAB adopted the WCJ's report and denied reconsideration.