Edgar Grazziani — ADJ4061586, ADJ2051354

Psychologist lien claimant Azadeh Rahimi, Ph.D. sought $36,650.00 for psychological evaluation and over 120 treatment sessions provided to applicant Edgar Grazziani between 12/18/09 and 7/11/16 for psyche injuries stipulated to have arisen from both a specific (5/22/00) and continuous trauma (3/15/02-3/15/03) injury. The WCJ allowed reimbursement only for the initial comprehensive evaluation/report at the stipulated value of $2,061.46 (plus penalties and interest), but disallowed all subsequent treatment and reporting due to lack of properly served Requests for Authorization (RFAs) and absence of proof of service for the 120+ single-page treatment reports. The lien claimant petitioned for reconsideration, arguing the evidence did not support disallowing the later treatment charges. The Board denied reconsideration, adopting the WCJ's report and noting that the one-page treatment reports were not correctly addressed letters entitled to the mailbox presumption under Evidence Code section 641, and there was no proof of service or mailing in the record. The Board emphasized the lien claimant bore the burden of proving service of all relevant documents and failed to do so.