Henry Castro — ADJ2353035, ADJ3567848, ADJ3208077, ADJ1325052

Lien claimant Charles Schwartz, MD, was applicant Henry Castro's primary treating physician across four consolidated claims against Franklin Truck Parts (insured by State Compensation Insurance Fund), all resolved via a single $210,000 compromise and release. The sole issue was whether Dr. Schwartz's liens should be dismissed for untimely or prematurely filed declarations under Labor Code sections 4903.05 and 4903.8. The WCJ ultimately found the liens were not dismissed, and defendant sought reconsideration. The Board denied reconsideration, holding that filing a declaration before the lien was of no legal consequence under liberal pleading principles, that medical treatment is not apportionable so only one properly filed lien was needed, and that only one filing fee was required for the duplicative liens. The Board found at least one properly filed, declaration-compliant lien existed (the April 30, 2022 filings), making any earlier procedural deficiencies immaterial.