WCPanelIQ
PanelMed-legalLienGranted

Miguel Del Rio — ADJ8293451

MIGUEL DEL RIO, Applicant vs. VALLARTA SUPERMARKETS; SAFETY NATIONAL CASUALTY COMPANY, administered by CORVEL, Defendants

ADJ number
ADJ8293451
Decision date
Apr 5, 2026
District office
Los Angeles
WCJ
—
Claim administrator
CorVel (administering for Safety National Casualty Company); Sedgwick referenced as bill processor
Commissioners
KATHERINE A. ZALEWSKI, CHAIR, LISA A. SUSSMAN, DEPUTY COMMISSIONER, PAUL F. KELLY, COMMISSIONER
LC §3205.5LC §4603.3LC §4620LC §4621LC §4622LC §5313LC §5705.5LC §5803LC §5900LC §5901LC §5903LC §5907LC §5908LC §5908.5LC §5909LC §5950LC §5952CCR §9794CCR §10451.1CCR §10600

Summary

Cost petitioner Supreme Copy Service, a copy/records service provider, sought reconsideration of a WCJ's December 31, 2025 Findings and Order that found defendant timely objected to two invoices and that cost petitioner failed to timely seek a second bill review. The disputed charges involved four SDT-related invoices for records copying services in a case settled by Compromise and Release in 2014. Cost petitioner argued defendant's Explanations of Review (EORs) were defective, lacked proof of service, and were never received, so it was not required to seek second bill review. The Board granted reconsideration, noting that two EORs appeared untimely (served outside the 60-day window) while others involved second bill review requests filed years late, and that the record lacked any testimony or evidence of mailing/service of the EORs. The Board deferred a final decision pending further development of the record and review of the merits.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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