Leon Simpson — ADJ9838074, ADJ9838134

Citywide Scanning Service, a copy/medical-legal records provider, sought reimbursement of $10,718.55 for records services in the case of deceased applicant Leon Simpson. Citywide accidentally filed its Petition for Determination of Non-IBR Medical-Legal Dispute under the wrong case (Maria Godinez), which the WCJ treated as a jurisdictional defect, finding Citywide failed to meet its burden and imposing sanctions and costs totaling $8,750 against Citywide and its hearing representatives. On reconsideration, the Board held the WCAB possesses subject matter jurisdiction over medical-legal disputes, that no statute of limitations or jurisdictional time limit applies to such petitions, and that the misfiled petition combined with the DOR gave sufficient notice to satisfy due process. The Board rescinded the Findings, Order, and the sanctions order for lack of due process notice and remanded for trial on the merits in light of Colamonico. The Petition for Disqualification was denied. The grant of reconsideration in the companion case ADJ9838134 was vacated.