Teresa Gonzalez Grant Dec — ADJ12859017, ADJ12859018

Applicant Teresa Gonzalez sustained a cumulative trauma injury (CT 12/31/1995–11/13/2019) to her lumbar spine, right shoulder, and bilateral wrists, plus a stipulated 4/3/14 specific injury, while working as a Tech #2 for Arconic Fastening Systems. The WCAB granted reconsideration of the September 22/24, 2021 Findings and Award in ADJ12859018 to address two credit disputes: a temporary disability overpayment credit (12/8/20–3/1/21) and a permanent disability advance credit from the companion case ADJ12859017. Applying J.C. Penney v. WCAB (Edwards), the Board disallowed the TD overpayment credit for 12/8/20–2/15/21 (because defendant failed to object to treating physician Dr. Luciano's reports under LC 4062) but allowed credit for 2/16/21–3/1/21 (because AME Dr. Silbart's definitive 2/15/21 report found applicant P&S). The Board affirmed the WCJ's allowance of PD advance credit across cases under LC 4909, distinguishing Dunehew, Benson, and Maples. The petition was granted in part and denied in part.