WCPanelIQ
En BancLienDenied

Hernandez Pedro

PEDRO HERNANDEZ, Applicant vs. HENKEL LOCTITE CORPORATION; ZURICH AMERICAN INS. CO., administrated by ZURICH NORTH AMERICA/LOS ANGELES, Defendants

ADJ number
—
Decision date
Date unavailable
District office
Pomona
WCJ
—
Claim administrator
Zurich North America/Los Angeles (administrator for Zurich American Ins. Co.)
Commissioners
—
LC §115LC §111LC §4903LC §4903.05LC §4600LC §4603.6LC §4610LC §4610.5LC §5307LC §5313LC §5708LC §5900LC §5902LC §5903LC §3600.5CCR §10341CCR §10770.7CCR §10770CCR §10508CCR §10392CCR §10848CCR §10856

Summary

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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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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