Perez, Tyson

Defendant Chicago Dogs (insured by Liberty Mutual) sought reconsideration of a WCJ's May 13, 2025 Findings and Order holding that the WCAB had personal jurisdiction over the team for applicant Tyson Perez's cumulative trauma claim as a professional baseball player. At trial, the WCJ refused to admit the affidavit of the team's COO, Trish Zuro, and refused to allow her to testify by telephone because the team had not filed a petition showing good cause for electronic testimony under WCAB Rule 10817(a). The Board, sitting en banc, granted reconsideration, preliminarily concluding that a request on the record for electronic witness testimony at the beginning of the hearing, with opportunity for parties to respond, satisfies the Rule 10817 petition requirement, and that the due process right to a fair hearing constitutes good cause to allow electronic testimony. The Board deferred a final decision on the merits pending further review of the entire record. A companion order corrected clerical references (Rule 10818 to 10618, and Rule 10817(c) to 10817(a)).