Carlos Garcia Duenas — ADJ10746669

Lien claimant Prime Physical Therapy Network sought reconsideration of a WCJ's July 28, 2022 Findings and Order disallowing its lien for services rendered by Absolute PT and Rehab Center, on the grounds that it failed to prove it was contractually entitled to payment under Labor Code section 4903(b). The lien claimant relied on Rebolledo I to argue it was a non-attorney collector/representative entitled to payment, but that panel decision had been rescinded and replaced by Rebolledo II before the lien claimant filed its brief. The Board acknowledged that under Rebolledo II a billing service may be the 'owner of the lien' under section 4903.8(a)(1) and entitled to payment, subject to proof. However, the lien claimant produced no evidence (testimony or documentation) establishing its ownership interest or entitlement to payment. The Board adopted the WCJ's Report and denied the Petition for Reconsideration because the lien claimant failed to meet its burden of proof.