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PanelGranted

Valencia, Noe

NOE VALENCIA, Applicant vs. TRAFFIX DEVICES, INC.; GREAT AMERICAN ASSURANCE COMPANY, Defendants

ADJ number: ADJ10934327
Decision date: Dec 3, 2025
District office: Anaheim
WCJ: —
Claim administrator: Great American Assurance Company
Commissioners: JOSÉ H. RAZO, COMMISSIONER, KATHERINE A. ZALEWSKI, CHAIR, JOSEPH V. CAPURRO, COMMISSIONER

CCR §10945CCR §10955

Summary

Applicant Noe Valencia sought to depose the claims adjuster in support of a petition for penalties and/or sanctions, but the WCJ quashed the deposition subpoena, finding no good cause. Applicant filed a petition for removal, arguing the deposition was reasonably calculated to lead to admissible evidence and was necessary for his penalty petition. The Appeals Board granted removal, finding the quash order violated applicant's due process right to depose witnesses and constituted irreparable harm. The Board rescinded the WCJ's order and substituted a new order denying defendant's petition to quash, while noting that defendant's verified petition appeared to contain a fabricated case citation and fabricated quotation. The matter was returned to the trial level to determine the nature of the apparent misconduct and take appropriate action, and the Board admonished attorney Lisa Peterson and the firm Michael Sullivan & Associates against filing fabricated citations.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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Similar decisions

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Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.