Lien claimant Monrovia Memorial Hospital filed its Supplemental Lien Form and section 4903.05(c) declaration on Monday, July 3, 2017, after the statutory deadline of July 1, 2017, which fell on a Saturday. Defendant petitioned for reconsideration arguing the lien was dismissed by operation of law because the declaration was untimely (due by June 30, 2017) and unsigned in violation of section 4903.05(c)(3). The WCAB, sitting en banc, held that section 4903.05(c)(2)'s 'until July 1, 2017' language established the last day for performance as July 1, 2017, and because that date fell on a Saturday when WCAB offices were closed, the deadline was extended to the next business day, Monday, July 3, 2017, under standard time-computation rules. The Board declined to address the electronic signature issue because the WCJ made no finding on it. The Petition for Reconsideration was denied.
Issues
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Holding
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Analysis
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Applicant takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Defense takeaway
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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Provider takeaway
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Similar decisions
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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The panel considered the record, the applicable statutes, and the arguments of the parties.
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