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PanelLienDismissed

Thanh Kim Thai — ADJ13421384

THANH KIM THAI, Applicant vs. MEGNA TOFU MANUFACTURING COMPANY; FARMERS INSURANCE, administered by BERKSHIRE HATHAWAY, Defendants

ADJ number: ADJ13421384
Decision date: May 3, 2026
District office: Pomona District Office
WCJ: —
Claim administrator: Berkshire Hathaway (administering for Farmers Insurance)
Commissioners: KATHERINE WILLIAMS DODD, COMMISSIONER, JOSEPH V. CAPURRO, COMMISSIONER, JOSÉ H. RAZO, COMMISSIONER

LC §5909LC §5900LC §5903CCR §10600CCR §10605CCR §10508CCR §10845CCR §10392

Summary

Lien claimant United Med Radiology Network sought reconsideration of a December 30, 2025 Order dismissing its lien after it failed to appear at an in-person lien conference on October 7, 2025, which led to a Notice of Intention to Dismiss issued November 7, 2025. The lien claimant argued it timely objected and did not receive notice of the December 30, 2025 hearing. The WCAB found the Petition for Reconsideration, dated February 19, 2026, was filed well beyond the 20-day statutory period (plus extensions) from the December 30, 2025 Order. Because the time limit is jurisdictional, the Board held it had no authority to consider the untimely petition and dismissed it. The Board noted the lien claimant could file a petition to set aside the order based on improper service, if pursued in good faith.

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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Similar decisions

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Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.

Full case search with summaries, PDFs, holdings, and filters is included with Member. This block is a decorative placeholder so the page layout is visible without exposing restricted text. Sign in or subscribe to Member to read the complete decision. The panel considered the record, the applicable statutes, and the arguments of the parties. Member is $25/month or $250/year and includes the weekly email digest, full case search, and bookmarks.