Miguel Damian — ADJ8866704, ADJ9030274

Supreme Copy Service, a copy service cost petitioner, sought reconsideration of a WCJ's Joint Findings and Order finding it failed to prove a contested claim existed at the time it incurred medical-legal copy service expenses. The WCJ had reasoned that ADJ8866704 (left thumb) was accepted with benefits paid on May 22, 2013, so no contested claim existed when subpoenas issued on May 30-31, 2013. The Appeals Board disagreed, finding defendant accepted only the left thumb injury (not the hand), disputed temporary disability throughout the case, and disputed all liability in the companion ear-injury claim (ADJ9030274). The Board held a contested claim existed under Labor Code section 4620 and that copy service lien claimants need not justify each individual subpoena given the liberal discovery policy. The Board granted reconsideration, rescinded the F&O, and substituted a new finding that the cost petitioner met its burden, deferring all other issues.