QME chiropractor Rex Lockwood, D.C., was paid $910.00 (two hours at $455/hour) in advance of a September 27, 2021 deposition that aborted due to technical connection failures; Lockwood prepared for an hour and waited 30-40 minutes but could not connect. When defendant rescheduled the deposition for May 19, 2022, it refused to advance a second $910.00 payment, arguing the prior payment satisfied its obligation and that Lockwood never gave 'medical-legal testimony.' The WCJ found defendant must advance an additional $910.00 minimum two-hour fee under AD Rule 9795 as a condition of taking the deposition. Defendant petitioned for removal, which the Board deemed a petition for reconsideration because it determined liability. The Board adopted the WCJ's report and denied the petition, holding Lockwood was entitled to a separate two-hour minimum fee for the second deposition because the aborted first deposition (which involved compensable preparation and waiting time) did not abrogate the advance-payment obligation for the second.
Issues
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Holding
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Analysis
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Applicant takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Defense takeaway
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Provider takeaway
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Similar decisions
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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