Asenji Kesheshi — ADJ8750331

Lien claimant Dental Trauma Center and defendant State Compensation Insurance Fund signed a 'Stipulation and Order to Pay Lien Claimant' on April 13, 2017, settling a $17,707.03 lien for $8,500.00, which was later modified on September 21, 2017 to remove the 30-day payment/penalties-and-interest provision. After signing, defendant's representative realized the lien may have been barred by the statute of limitations (last date of service October 30, 2013; lien filed June 16, 2015) and sought to declare the settlement null and void. The WCJ found the lien barred by the statute of limitations and the September 21, 2017 modification invalid. On reconsideration, the WCAB applied contract principles and Weatherall, finding no good cause to set aside the stipulation because defendant's failure to discover the statute of limitations issue resulted from its own lack of due diligence rather than a cognizable mistake. The Board amended the findings to hold lien claimant entitled to $8,500.00, deferred the penalties and interest issues, and returned the matter to the trial level.