Ramrakha, Michael

Michael Ramrakha, a correctional officer for CDCR, sustained industrial cardiovascular and hematopoietic injuries across three claims: a 9/16/01 specific injury (ADJ1415534, 25% PD), a 3/16/03 specific injury (ADJ4508242, 4% PD), and a cumulative trauma from 3/17/03 to 2/3/13 (ADJ8919366, 53% PD). Defendant overpaid permanent disability indemnity, primarily on the 3/16/03 claim, and sought credit under Labor Code section 4909 against the other two claims. The WCJ denied all credit, faulting defendant for late filing of its credit petition and for impairing applicant's awards. On reconsideration, the Appeals Board held that defendant was entitled to credit in ADJ1415534 (the 9/16/01 claim) because the overpayments on the two specific injuries, considered together, fully compensated applicant without impairing his ultimate award, but affirmed denial of credit in the cumulative trauma case (ADJ8919366) because allowing it would materially impair (roughly 20%) applicant's PD award there.