Berrios, Jose

Two cumulative/specific injury claims of a deli clerk (1996 and 1997 dates of injury) were settled by an amended Compromise and Release approved April 22, 2021, allowing a $90,000 attorney fee held in trust pending resolution of a fee dispute between applicant's former attorney (Ronald Ehrman) and current attorney (Ronald Nolan). The WCJ found that, under Labor Code section 4906(i), Nolan was precluded from any fee because he did not file a compliant disclosure form until October 16, 2023—approximately 2.5 years after the C&R—and awarded the entire $90,000 to Ehrman, who had filed a compliant disclosure in 1998. Nolan petitioned for reconsideration, arguing the WCJ erred in barring his fee and in awarding the full amount to Ehrman. The Appeals Board granted reconsideration, finding the WCJ's decision was not supported by substantial evidence without further development of the record, and noting equitable considerations and possible relief under Code of Civil Procedure section 473. The Board deferred a final decision after reconsideration pending further review.