Jose Badillo — ADJ11287164, ADJ11286905

Applicant Jose Ramos Badillo claimed industrial injury including injury to his teeth (bruxism) arising from his work as a sander, which defendant accepted as to orthopedic body parts but denied as to the teeth. After settling the underlying claims by C&R, a lien trial proceeded on the dental treatment lien of Mayer Schames, D.D.S. dba The Dental Trauma Center (DTC) and the EDD lien for benefits paid. The WCJ found injury to the teeth as a compensable consequence, found DTC's treatment reasonable, awarded DTC $12,289.29 plus penalties/interest, and awarded EDD $20,384.00 plus interest, rejecting defendant's statute of limitations defense. The WCAB denied defendant's Petition for Reconsideration, finding substantial evidence supported the dental injury (bruxism caused by industrial pain and stress), upheld the WCJ's discretion in accepting the lien claimant's bill reviewer as a witness, and held the EDD lien was not time-barred because defendant had timely notice and agreed to hold applicant harmless in the C&R.