Michael Crough — ADJ2403735, ADJ4645734

Defendant CIGA (administering claims for the insolvent Fremont Insurance Company on behalf of McDonnell Douglas/Boeing) sought reconsideration of Joint Findings of Fact denying it permanent disability advance credits in two consolidated cases. In ADJ2403735, defendant sought a $25,045 credit (originally framed as a $34,738.40 credit/$10,693.40 overpayment) that had already been adjudicated and denied by a WCJ in November 2024 and affirmed by the Board in February 2025 without judicial review. In ADJ4645734, defendant sought an additional $18,601.99 credit beyond the $13,370 advance specified in a 1991 Stipulation with Request for Award. The Board granted reconsideration but affirmed the denial of credits, amending the ADJ2403735 finding to hold that defendant was precluded (by finality/collateral estoppel principles) from re-asserting the credit issue. The Board further deferred and remanded the issues of section 5813 sanctions, section 5814 penalties, and section 5814.5 attorney's fees, finding defendant's relitigation of a finally-decided issue and refusal to pay the award potentially frivolous.