Cazares Meza, Maria Del Pilar

Maria del Pilar Cazares Meza sustained an industrial injury on March 31, 2022 while working as an agricultural laborer at West Coast Berry Farms, injuring her neck, back, right shoulder, right wrist, right knee, and suffering headaches. The WCJ found 64% permanent disability based on the primary treating physician's report and declined to apportion under Labor Code section 4664. Defendant sought reconsideration, arguing the treating physician's report was not substantial medical evidence because the physician lacked apportionment information, and that the WCJ erred by not apportioning to prior awards under section 4664. The Appeals Board first addressed timeliness, finding the petition timely due to the 10-day extension for out-of-state service, then denied reconsideration on the merits because defendant failed to meet its burden of proving apportionment. The Board found defendant did not produce prior awards of disability (only Compromise and Release agreements without stated PD levels) and failed to obtain medical opinion on overlap.