Craig Markowski — ADJ6994280

Applicant Craig Markowski sustained a February 20, 2008 industrial injury while employed by Cedars-Sinai Medical Center (permissibly self-insured), settling the employer claim via a $550,000 Compromise and Release approved April 2, 2019. The WCJ awarded SIBTF benefits, finding a 42% pre-existing permanent disability that combined with the 93% subsequent industrial disability to produce 100% permanent total disability. SIBTF petitioned for reconsideration, challenging the finding of requisite labor-disabling pre-existing permanent disability and the combination methodology. The Board granted reconsideration and rescinded the decision because the electronic record was incomplete—Dr. Markovitz's March 30, 2011 internal medicine report (Exhibit 5) was missing, with a duplicate of Exhibit 4 in its place. The Board also returned the matter for development of the record and reanalysis of whether applicant had labor-disabling permanent disability immediately prior to the subsequent injury under the governing authorities.