WCPanelIQ
PanelLienGranted in Part

Brager, Eric

ERIC BRAGER, Applicant vs. RKL TECHNOLOGIES, Defendants

ADJ number
—
Decision date
Nov 2, 2025
District office
Oxnard
WCJ
Michael Greenberg
Claim administrator
—
Commissioners
JOSEPH V. CAPURRO, COMMISSIONER, CRAIG L. SNELLINGS, COMMISSIONER, JOSÉ H. RAZO, COMMISSIONER
LC §5311LC §5313LC §5900LC §5902LC §5903LC §5909LC §5952CCR §10600CCR §10843

Summary

Liaison counsel for carriers sought reconsideration or removal of an August 1, 2025 Discovery Order issued by a WCJ in a consolidated lien matter. The Discovery Order voided all prior orders of WCJ Tammy Homen (who had recused herself after a Petition for Disqualification alleging her husband's involvement in some consolidated cases and a prejudicial off-the-record comment), ordered misfiled documents refiled into the correct case record (SAU8840977 rather than ADJ8840977), and threatened sanctions for noncompliance. The Board denied reconsideration because the Discovery Order was not a final order, but granted removal, finding the order was issued without notice, a hearing, findings of fact, or an opinion on decision, in violation of due process. The Board rescinded the Discovery Order and returned the matter to the trial level for proper notice and a fair hearing on whether WCJ Homen's prior orders were truly 'tainted.'

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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