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PanelLienDenied

Jose Guzman — ADJ6693717

JOSE GUZMAN, Applicant vs. DE LA TORRE LANDSCAPE & MAINTENANCE; BERKSHIRE HATHAWAY HOMESTATE COMPANIES, Defendants

ADJ number: ADJ6693717
Decision date: Aug 4, 2022
District office: Marina del Rey
WCJ: Jared E. Klipfel
Claim administrator: Berkshire Hathaway Homestate Companies
Commissioners: —

Injury / body parts: low back

LC §4903.05LC §4903.06

Summary

Lien claimant Professional Interpreting filed a lien for interpreting services in Jose Guzman's workers' compensation case (cumulative low back injury, April 20, 2007 to November 3, 2008). The lien was originally filed on August 1, 2012, with a lien activation fee paid on January 14, 2015. The WCJ found the lien dismissed by operation of law as of July 3, 2017, due to failure to comply with the declaration requirement of Labor Code section 4903.05(c)(3). Professional Interpreting argued that because it paid an activation fee (under section 4903.06) rather than a filing fee (under section 4903.05), it was exempt from the section 4903.05(c)(3) declaration requirement. Relying on Ida Montelongo v. Gelson's Market (2022 Cal. Wrk. Comp. P.D. Lexis 41), the WCJ rejected this argument, and the WCAB denied reconsideration, adopting the WCJ's report.

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.