Iman Larki — ADJ10529726, ADJ10554062

Lien claimant Azadeh Rahimi, Ph.D., a psychologist, sought $30,050.00 for counseling services provided to applicant Iman Larki, a tow truck driver who filed two specific injury claims later settled by compromise and release. At trial on the lien, the WCJ found Dr. Rahimi's single narrative report inadmissible because she was not the designated primary treating physician (Roberto Morales, D.C. was), there was no PTP referral to her, and her report was never incorporated or commented on by the PTP. With the only causation report stricken, the lien claimant failed to meet its burden to prove a compensable psychiatric injury, resulting in a take-nothing order. The WCAB adopted the WCJ's report and denied reconsideration, holding that AD Rule 9785(e)(4) renders such reports inadmissible and the bills unpayable. The statute of limitations issue was rendered moot.