Jennifer Lee Reino D&i — ADJ3362746, ADJ2142330, ADJ2701589, ADJ915001

Applicant Jennifer Lee Reino had a 1990 Joint Stipulations with Request for Award in which two defendants, Vons and Armstrong World Industries, agreed to each be responsible for 50% of the cost of future medical care. In 2009, Vons and the applicant entered into a bilateral Compromise & Release that did not include Armstrong. After Armstrong administered future medical care for years and sought 50% reimbursement from Vons, the WCJ found Vons remained obligated for its 50% share, holding that the bilateral C&R did not extinguish the three-way 1990 award. Vons petitioned for reconsideration, raising statute of limitations, laches, waiver, contract law (novation), and a prior arbitrator's order as defenses. The WCAB adopted and incorporated the WCJ's Report and Opinion (except one paragraph under 'Application of Contract Law') and denied reconsideration, finding the 1990 Award enforceable against Vons.