Kreza, Michael

Michael Kreza, a firefighter, died after being struck by a car while bicycling off-duty; his dependents pursued a death claim that was initially denied at trial but later found compensable on reconsideration and affirmed when writ review was denied. After the parties submitted proposed stipulations, the WCJ issued an Order Suspending Action stating the requested 15% attorney's fee was 'excessive for a death claim' and suggesting 3% to 9% would be reasonable. Applicant sought reconsideration, removal, and disqualification of the WCJ, arguing the Order reflected an unqualified, prejudgment opinion creating the appearance of bias. The Appeals Board dismissed the petition for reconsideration because the Order was not final, but granted removal and disqualification, finding the WCJ's fixed language declaring fees excessive—before any hearing or evidence review—created an appearance of bias. The Board rescinded the Order, disqualified the WCJ, and returned the matter to the Presiding WCJ for reassignment.